February 22, 2016 U.S

. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington,
DC 20590 Re: Petition ofMBVideoDrone

for an Exemption Pursuant

to Section 333 of the FAA Modernization
and Reform Act of2012 Director

: Flight Standards Service: Pursuant

to Section 333 of the FAA Modernization
and Reform Act of2012 ("Reform Act") and 14 C

. F.R. Part 11, MBVideoDrone ("Petitioner") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation
of small unmanned aerial vehicles (i.e., "small unmanned aircraft"
or "UAS") for the purpose of conducting aerial photography, videography,
and inspections
for residential, commercial real property and construction projects for the real estate and construction industries. This petition for exemption

is made based on information outlined

in this Petition for Exemption

, as well as the accompanying Petitioner documents; 1 . PIC Flight Operations Manual and

; 2 . Operations Manuals (Collectively

2 and 3 are referred

to as "Docwnents

& Manuals") 3. User Guide and; 4. Flight Manual' (Collectively

3 and 4 are referred

to as "Manufacturer's Manuals") Petitioner submits these supporting materials

as confidential documents pursuant

to 14 C.F.R

. § 11.35(b

) , as the materials contain confidential commercial and/or proprietary information that Petitioner has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available

to the public and are protected from release under the Freedom
of Information Act,
5 U

. S.C.

§ 552 et. seq .. NOTE: ALL ATTACHMENTS
SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIAL
AND SHALL NOT BE RELEASED
TO THE PUBLIC WITHOUT WRITIEN AUTHORIZATION FROM THE PETITIONER. For your convenience,
this Petition

is organized

as follows: 1 • The term "Manufacturer's Manual" also includes
all relevant manufacturer publication

s , including, but not limited to: operations and flight manuals

, user guides, component maintenance manual

s, pilot training manuals, service information letters and, safety/servic

e bulletins

.U.SDepartmentof.TransportationFebruary22,2016Page2I.DescriptionofPetitionerD.DescriptionofProposedOperationsA.AerialVideography,PhotographyandInspectionDI.RelevantStatutoryAuthorityIV.Petitioner'sProposedUASOperationsMeettheRequirementsofSection333OftheReformActA.ApprovalisWarrantedBasedontheUAS'sSize,Weight,Speed,andOperationalCapabilityB.ApprovalisWarrantedBasedontheOperationalRestrictionsSetForthintheOperationsManualsV.RegulationsFromWhichExemptionisRequestedA.14C.F.R.Part21,SubpartH-AirworthinessCertificatesand14C.F.R.§91.203(a)(1)B.14C.F.R.Part27AirworthinessStandards:NormalCategoryRotorcraftC.14C.F.R.§§91.9(c),45.23(b)and45.27(a):AircraftMarkingandIdentificationRequirementsD.14C.F.R.§91.405(a),91.407(a)(1),91.409(a)(l)and(2);91.417(a)and(b):MaintenanceInspectionsE.14C.F.R.Part61,14C.F.R.§61.3,14C.F.R.§61.113:PrivatePilotPrivilegesandLimitationsF.14C.F.R.§91.7(a):CivilAircraftAirworthinessG.14C.F.R.§91.9(b)(2):CivilAircraftFlightManualintheAircraftand14C.F.R.§91.203(a)and(b):CarryingCivilAircraftCertificationandRegistrationH.14C.F.R.§91.103:PreflightActionI.14C.F.R.§91.109{a):FlightInstructionJ.14C.F.R.§91.119(c):MinimumSafeAltitudesK.14C.F.R.§91.121:AltimeterSettingsL.14C.F.R.§91.151(a):FuelRequirementsforFlightinVFRConditionsVl.DrugandAlcoholProgramVD.PublicInterestVDI.PrivacyIX.FederalRegisterSummaryX.ConclusionI.DESCRIPTIONOFPETITIONERPetitionerisbasedinPalmdale,CAworkinginaerialphotography,videography,andinspectionsforresidential,commercialrealpropertyandconstructionprojectsfortherealestateandconstructionindustries.TheCompanyspecializesin,andwillcontinuetofocusontheI
U.S Department ofTransportation February 22, 2016 Page3 photography, videography
and inspection
of real property and construction sites for the real estate and construction industries

. The Company's Principal and Chief Pilot Mark Barrows has been flying UAV Quadcopters

as a hobby for more than one year without incident, logging hundreds ofhours flying. Upon the grant of the 333 Exemption the Company's business will specialize

in photography, videography
and inspection
of real property and construction sites. Petitioner's staff are well trained and experienced

in providing support
as visual observers ("VO") for the pilot in command ("PIC')

in addition

to any other needed on site assistance. All of the equipment owned by Petitioner

is of the highest quality gear and has been able to provide these services safely and without any claims or incident. Petitioner's goal is to advise the perspective client that Petitioner

is following
all the applicable state and federal rules to ensure the safety of the public while providing the client with

a competitive and cost effective product. Petitioner seeks an exemption

to allow for photography, videography
and other related media products. The contact information
for Petitioner

is as follows: Mark Barrows MBVideoDrone 38734 174 111 Street E. Palmdale, CA 93591 Phone: 818.836.4828: Email: cal64kid@gmail.com II. DESCRIPTION

OF PROPOSED OPERATION Petitioner seeks an exemption pursuant

to Section 333 of the Refonn Act to operate the Yuneec Q500 4k (referred

to MB-UAS) (under 5Slbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions
on private property
or approved location where Petitioner has received verifiable permission

to operate from the landowner, controller

or authorized representative.
The proposed UAS operations will be conducted

in accordance with the conditions and limitations
of this Petition for Exemption and Petitioner's Operations Manuals. As detailed
in Petitioner's Operations Manuals,
all UAS operations will be limited
to daytime VFR conditions, within visual line-of-sight ("VLOS")
of the operator,

in uncontrolled airspace, and will occur at least
5 nm away from an airport reference point. Moreover, Petitioner's Operations Manuals incorporate redundant safeguards

to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. A. Aerial Videography, Photography and Inspection Petitioner seeks to use small MB-UAS for the purpose of conducting aerial photography, videography and inspection for the real estate and construction industry. Petitioner hasU.SDepartmentofTransportationFebruary22,2016Page4purposefullytailoreditsoperationstomeettherequirementsestablishedbytheFAAinpriorgrantsofexemptionauthorizingcommercialuseofUASintherealestateindustry,including:•Trudeau,Realtor®(ExemptionNo.11138)•AlonSicherman(ExemptionNo.11728)•SokolerMedly(ExemptionNo.11341)•RavenExecutive(ExemptionNo.12639)AllUASphotography,videographyandinspectionoperationswilloccuronprivatepropertyorapprovedlocationinacontrolledareaawayfromspectatorsandpersonsnotinvolvedintherecordingprocess.Inaddition,thefilmingwillbeconductedbetweendawnanddusktoensuremaximumsafetyforthepublicandthoseinvolvedinthemanipulationandoperationoftheUAS;VFRconditions,ataltitudesbelow400'abovegroundlevel("AGL").Assetforthbelow,Petitioner'soperationsprovideanequivalentlevelofsafetywhichissuperiortoperformingthesameworkusingconventionalfixed-wingaircraftorhelicopters.SmallUASvideoproductionisalsosaferthantraditionalmannedaircraftperformingthesamefunction.Videographer-inspectorsalsofrequentlyneedtoclimbrooftops,trees,laddersorotherwiseperformelevatedwork,whichexposesthemtotheriskofdangerousfalls,electrocutionorotherworkrelatedinjuries.Inaddition,dependingonthenatureofthevideoneededandinspection,proximitytoequipment,andothermechanicalhazardsassociatedwithindustrialsitesandconstructionfacilitiesofteninvolvesariskofexposuretohazardousconditions.TheuseofMB-UASmitigatesthesehazardsandisultimatelyamuchsaferandcostefficientmethodofperformingtheseandmostothertypesofinspections.Moreover,conventionaloperationsusingrotorcraftandfixed-wingaircraftinlowleveloperationspresentrisksassociatedwithvehiclesweighingtensofthousandsofpounds(includingpayload)andcarryinglargeamountsoffuelwhichinherentlypresentssignificantfirehazardsaswellasexposuretootherchemicalcontaminates.ItisimportanttonotetheuseofsmallUASinthisareawillnotonlybesaferandmorecosteffectivetotheperspectiveuserorpurchaseroftheservice,butthequalityandexpanseofacquiredinformationwillbefarmorerobustgiventhelowcostassociatedwithitsacquisitionandotherpotentialconsumersaninexpensiveproduct.UASvideoproductionismorereliable,andallowsforthecollection,dissemination,andstorageofvisualandothersensorydatawithgreaterprecisionanddurationataverylowcost.SmallUASswillalsobecapableofaccessingandinspectingareasthatwouldotherwisebeinaccessibleorhighlydangeroususingconventionalaircraftorotherinspectionmethods.III.RELEVANTSTATUTORYAUTHORITYThisPetitionforExemptionissubmittedpursuanttoSection333(a)through(c)oftheFAAModernizationandReformActof2012("ReformAct").CongresshasdirectedtheFAA"tosafelyacceleratetheintegrationofcivilunmannedaircraftsystemsintothenationalairspacesystem."PursuanttoSection333oftheReformAct,theFAAAdministratoristopermitunmannedaircraftsystemstooperateintheNationalAirspaceSystems("NAS")whereitissafetodosobasedonthefollowingconsiderations:U.SDepartmentofTransportationFebruary22,2016PageS•TheUAS'ssize,weight,speedandoperationalcapability;•OperationoftheUASincloseproximitytoairportsandpopulatedareas; and•OperationoftheUASwithinthevisuallineofsightoftheoperator.Additionally,theFAAAdministratorhasgeneralauthoritytograntexemptionsfromtheagency'ssafetyregulationsandminimumstandardswhentheAdministratordecidesarequestedexemptionisinthepublicinterest.See49U.S.C.§106(f)(definingtheauthorityoftheAdministrator);49U.S.C.§44701(f)(permittingexemptionsfrom§§44701(a),(b)and§ §44702-44716,etseq.).Apartyrequestinganexemptionmustexplainthereasonswhytheexemption:(1)wouldbenefitthepublicasawhole,and(2)wouldnotadverselyaffectsafety(orhowitwouldprovidealevelofsafetyatleastequaltotheexistingrules).See14C.F.R.§11.81(petitionsforexemption).IV.PETmONER'SPROPOSEDMB-UASOPERATIONSMEETTHEREQUIREMENTSOFSECTION333OFTHEREFORMACTThesmallMB-UASoperationsproposedbyPetitionerasnotedaboveinthisPetitionforExemptionqualifyforexpeditedapprovalpursuanttoSection333oftheReformActaseachofthestatutorycriteriaandrelevantfactorsaresatisfied.A.ApprovalisWarrantedBasedontheUAS'sWeight,Speed,andOperationalCapabilityAGrantofExemptionisappropriateforoperationsconductedusingtheUASsduetotheirsizeweight,speed,andoperationalcapability.•TheMB-UASutilizedbyPetitionerhasbeenapprovedforuseinpriorSection333GrantsofExemptionfromtheFAA.2•TheMB-UASweighslessthan55pounds,includingpayload•TheMB-UASwillnotbeflownatagroundspeedinexcessof87knots(100mph).Theexemptionholdermayuseeithergroundspeedorcalibratedairspeedtodeterminecompliancewiththe87knotspeedrestriction.•AltitudeinformationwillbegeneratedbyequipmentonboardtheUASasspecifiedusingGPStriangulation,digitallyencodedbarometricaltimeter,radioaltimeter,oranycombinationthereof.Thisinformationwillbetransmittedtothepilotviatelemetricdatafeed.•TheMB-UASwillhavesystemredundanciesandindependentfunctionalitytoensuretheoverallsafetyandpredictabilityofthesystem.Ifconnectiontotheremote2Seee.g.,GrantofExemptiontoTrudeau,Realtor®(ExemptionNo.11138);GrantofExemptiontoAlonSicherman(ExemptionNo.11728);GrantofExemptiontoSoko1erMedly(ExemptionNo.11341).U.S Department

of Transportation February 22,2016 Page6 control
or ground control station

is lost, failsafe systems will permit the UASs to return to a predetennined location and safely land without injury or damage. • The radio frequencies used for operations and control of the MB-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements.
The operating frequency for the MBUAS is 2.4 GHz frequency bands

. If the same operations were conducted using

a helicopter, the aircraft's take-off weight would likely exceed 6,000 pounds depending
on payload. The difference

in weight between the MBUAS and
a helicopter significantly reduces the potential hann to the participating and nonparticipating individuals and/or surrounding property

in the event of an unintended accident
or incident.

In addition, the risk to the onboard pilot and camera operator

is eliminated. B. Approval

is Warranted Based on the Operational Restrictions
Set Forth in Petitioner's Operations Manuals Petitioner's Operations Manuals and the Manufacturer's Manual for the selected MB-UAS will contain all the procedures and limitations necessary

to safely and successfully perform the operations specified

in this Petition for Exemption

. To assist the FAA in making

a safety assessment

of Petitioner's proposed operations, below

is a summary
of operational limitations and conditions that Petitioner will adhere to, and which will ensure an equivalent

or higher level of safety
to operations conducted under current regulatory guidelines: 1. The MB-UAS weighs less than 55 pounds, with payload. 2 . All operations shall be conducted over private
or controlled-access property with verifiable permission from the land owner/controller

or authorized representative. Permission from land owner/controller

or authorized representative
will be obtained for each scheduled flight prior to operation. 3. All UASs operated under the Grant of Exemption will be identified
by serial number, registered

in accordance with 14 CFR part 47, and have identification (N-Number) markings

in accordance with 14 CFR part 45, Subpart
C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in Command ("PIC") of the MB-UAS, and one or more Visual Observers ("Observer") as necessary

to safely conduct the mission. 5. PICs shall possess either

a private, recreational,

or sport pilot certificate. The PIC must also hold

a current FAA airman medical certificate

or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico,

a territory,

a possession,

or the Federal government. The PIC will also meet the flight review requirements specified

in 14 C.F.R 61.56 in an aircraft
in which the PIC is rated on his or her pilot certificate.U.S Department

of Transportation February
22

, 2016 Page7

6 . The MB-UAS shall be operated within VLOS of the PIC and Observer

at all times. The PIC must use human vision unaided by any device other than corrective lenses

, as specified
on the PIC's FAA-issued medical certificate. 7 . The PIC and Observer designated
for any operation will be able to communicate verbally

at all times. 8. Electronic messaging

or texting will not be permitted during flight operations. 9 . The additional requirements identified

in the Grant of Exemption shall be added to the Petitioner's Operations Manuals. The Operations Manuals will be maintained and made available

to the Administrator upon request.
If a discrepancy exists between the conditions and limitations

in the Grant of Exemption and Petitioner's Operations Manuals, the conditions and limitations

in the Grant of Exemption shall take precedence and must be followed

. Otherwise, Petitioner shall follow the procedures outlined

in their Operations Manuals

. 1 0. Petitioner may update or revise its Operations Manuals. Revisions will be tracked and a revised copy of the Manual will be provided

to the Administrator upon request. Petitioner will also present an updated and revised Operations Manuals

if it petitions for extension

or amendment

to its Grant of Exemption.

If an update or revision would affect the basis upon which the FAA grants the exemption, Petitioner will seek an amendment

to its Grant of Exemption

. Petitioner will contact the FAA's UAS Integration Office (AFS-80)

if questions arise regarding updates or revisions
to the operating documents. 11. Petitioner Operations Manuals and its Grant of Exemption will be available

to the PIC at the ground control station anytime the MB-UAS

is operating. 12

. The PIC is prohibited from beginning

a MB-UAS flight unless (considering wind and forecast weather conditions) there
is enough power
to fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximum total flight time for each operational flight using the MB-UAS will be limited
to 40 minutes
or the amount of time the UAS can be flown and still maintain

a reserve battery power of no less than 25%, whichever occurs first. 14

. Flights will be operated

at an altitude of no more than 400 feetAGL and will never enter navigable controlled airspace without timely prior written authorization
and approval from the FAA

. In the event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure

. 15. Flight operations must be conducted

at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees
or essential persons), vessels, vehicles, and structures unless:U

. S Department

of Transportation February 22,2016 PageS

a. Barriers
or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris
in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection

. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft

is operated near vessels, vehicles
or structures where the owner/controller

of such vessels, vehicles
or structures has granted permission and the PIC has made

a safety assessment
of the risk of operating closer
to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, VO, operator trainees
or essential persons do not present an undue hazard
to those persons per
§ 91.119( a). 16. The MB-UAS 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. 17. The MB-UAS may not operate within

5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless

a letter of agreement with that airport's management

is obtained, and the operation

is conducted

in accordance with a NOTAM

as required by the FAA. The letter of agreement with the airport management will be made available

to the Administrator upon request. 18

. Prior to each flight the PIC shall inspect the MB-UAS

to confinn that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g

. inoperable components, items, or equipment,
not already covered

in the relevant sections of the operating documents

as well as equipment updates. The PIC shall not operate any MB-UAS

if the inspection reveals

a condition that affects the safe operation
of the MB-UAS until the necessary maintenance
has been performed and the MB-UAS

is found to be in a condition for safe flight. The ground control station shall be included

in the preflight inspection

. All maintenance
and alternations must be properly documented

in the UAS's records
as required
by Petitioner's Operations Manuals. 19

. Petitioner will timely carry out its maintenance, inspections, and record keeping requirements

in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the MB-UAS records, including total time in service, description

of work accomplished,
date completed and the signature
of the authorized person returning

the MB-UAS

to service. 20. Any MB-UAS that has undergone maintenance

or alterations that affect the UAS operation

or flight characteristics (e.g., replacement

of a flight critical component) must timely undergo

a functional test flight in accordance with Petitioner's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight The requirements
and procedures
for a functional test flight and MB-UAS record entry shall be included

in the Petitioner's Operations Manuals

.U.SDepartmentofTransportationFebruary22,2016Page921.TheMB-UASwillbeoperatedandmaintainedaccordingtotheManufacturer'sManualsand anyrequiredmanufacturerSafety/ServiceBulletinsandproductupdates.22.Priortotheoperation,aMissionPacketwillbecreatedinaccordancewiththerequirementsonPetitioner'sOperationsManuals.23.PetitionerwillobtainanAirTrafficOrganization("ATO")issuedCertificateofWaiverorAuthorization,otherwiseknownasaCOA,priortoconductinganyoperationsunderthisGrantofExemption.ANOTAMwillbeissuedasrequiredbytheCOA.AlloperationswillbeconductedinaccordancewithairspacerequirementsintheATOissuedCOAincludingclassofairspace,altitudelevelandpotentialtransponderrequirements.24.Allrequiredpermissionsandpermitswillbeobtainedfromterritorial,state,countyorcityjurisdictions,includinglocallawenforcement,fireorotherappropriategovernmental agencies.25.IftheMB-UASlosescommunicationwiththePIC,itwillhavethecapabilitytosafelyreturntoapre-determinedlocationwithintheoperationalareaandlandsafely.26.ContingencyplanswillbeinplacetosafelyterminateflightifthereisalossofcommunicationbetweenthePICandtheObserver.27.TheMB-UASwillhavethecapabilitytosafelyabortflightinthecaseofunpredictedobstaclesoremergencies.28.PICsandObserverswillhaveatleastacurrentClassIIIMedicalCertificateoravalidandcurrentstatedriver'slicenseissuedwithintheUnitedStates.29.Priortoconductingoperationsforfilming,thePICwillhaveaccumulatedandlogged,inamannerconsistentwith14CFR§61.51(b),aminimumof200flightcyclesand25hourstotaltimeasaUASrotorcraftpilotandatleast10hoursloggedasaUASpilotwithasimilarMB-UAStypeplatfonn.Thisrequirementcanbeachievedbyflightsconductedandloggedasahobbyist.30.Priortoconductingoperationsforfilming,thePICwillhaveaccumulatedandlogged,inamannerconsistentwith14CFR§61.51(b),aminimumofhourspursuantto54CFR§61.51(b)asUASpilotoperatingthemakeandmodelofMB-UAStobeutilizedforoperationsundertheexemptionandthreetake-offsandthreelandinginthepreceding90days.31.OperationsshalloccurduringdaytimeVFRMeteorologicalConditions;flightsunderspecialvisualflightrules("SVFR")shallnotbeconducted.32.TheMB-UASshallremainclearandyieldtherightofwaytoallothermannedoperationsandactivitiesatalltimes(including,butnotlimitedto,ultralightvehicles,parachuteactivities,parasailingactivities,hanggliders,etc.).U.S Department ofTransportation February 22, 2016 Page 10 33

. MB-UAS Operations wtder Instrument Flight Rules,
at night, or beyond VLOS are prohibited. 34. The UAS will not be operated from an elevated platform unless designed and engineered specifically
for such purposes and be in compliance with the general restrictions imposed
by the applicable regulations. Additionally

no PIC will provide any film-flight operations while in motion from atop any elevated platform vehicle or device. 35. Before conducting operations,
the radio frequency spectrum used for operation and control of the MB-UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. V
. REGULATIONS FROM WIDCH EXEMPTION

IS REQUESTED The Federal Aviation Act expressly grants the FAA the authority

to issue exemptions. This statutory authority,
by its terms, includes exempting civil aircraft,
as the term is defined wtder

§ 40101 of the Act, including UASs, from its safety regulations and minimum standards when the Administrator decides

a requested exemption

is in the public interest.

3 Petitioner seeks an exemption from several interrelated provisions ofTitle
14 of the Code of Federal Regulations ("14 C.F.R") Parts 21, 45,61 and 91 for purposes
of conducting
the requested operations using MB-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption

is sought, and (2) the operating procedures and · safeguards that Petitioner has established which will ensure

a level of safety better than or equal to the rules from which exemption

is sought.

4 UNMANNED AIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart

H
- Airworthiness Certificates and 14 C.F

. R. §91.203(a)(l) The FAA has stated that no exemption

is needed from this section
if a finding

is made under the Reform Act that the UAS selected provides
an equivalent level of safety when compared

to aircraft normally used for the same application. These criteria are met and in point of fact exceeded, and therefore no exemption

is needed.

s If, however, the FAA determines that there are some characteristics

of the chosen UAS that fail to meet the requirements

of the Reform Act, an exemption

is requested. 3 49 U.S

. C
. § 4470l(f) (authorizing
the grant of exemptions from requirements

of regulations prescribed pursuant

to Sections 4470l(a) and (b) and Sections 44702- 44716)

. 4 14 C

. F.R
§ 11

. 8l(e), which requires

a petition for exemption

to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide

a level of safety at least equal to that provided by the rule from which you seek exemption

. 5 See Grant of Exemption
No

. 11062 to Astraeus Aerial (FAA-2014-035

2 at pgs

. 13-14, 22).U.S Department

of Transportation February 22,2016 Page II Equivalent Level of Safety Petitioner's
use of the MB-UAS

is safe when taking into account
its size, weight, speed, and operational capability.
As set forth in the description

of proposed operations

in Section IV(A), the MB-UAS weighs less than 55 pounds, including payload and will not be flown
at a ground speed in excess of 50 knots. The MB-UAS

is also equipped with safety features which will allow Petitioner

to operate the MB-UAS safely after experiencing certain in-flight contingencies or failures
as noted below. 6 7 Additionally,

the MB-UAS carries neither pilots nor passengers, carries no explosive materials
or flammable liquid fuels, or other elements identified
by Homeland Security

as being prohibitive and operate exclusively within the parameters stated in Petitioner's Operations Manuals. Operations conducted under this exemption will be closely controlled and monitored
by the PIC operator and will be conducted

in compliance with local public safety requirements,

to provide security for the area of operation. Petitioner will also provide the FAA with advance notice of all operations
via NOTAMs

as required
by the applicable COA. In all cases, operation
of the MBUAS under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate. Lastly, the MB-UASs

do not need

a means to communicate with other aircraft
or ATC, because those capabilities will be solely possessed
by the PIC and Observer, who are not on board the MB-UAS.

8 In addition,
no sense-and-avoid technology

is necessary
for the MB-UASs because they will be operated

at all times in VFR conditions and within VLOS of the PIC and Operator.

9 6 See e.g., Grant ofExemption
No. 11184 to Low Country RC, Corp. (FAA-2014-0803

at pg. 3): "The [DTI SIOOO] has the capability

to operate safely after experiencing certain in-flight contingencies

or failures and uses an autopilot system
to maintain UAS stability and control. The UAS
is also able to respond
to a loss of global positioning system (GPS) or a lost-link event with

a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality

as a backup. These safety features provide
an equivalent level of safety compared

to a manned aircraft performing

a similar operation." 7 See e.g., Grant ofExemption
No. 11184 to VOOS Global, LLC

. (FAA-2014-0382

at pgs

. 4-5)

: "The MB-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The MB-UAS can be operated

in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create

a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes
so the system cannot enter areas deemed unsafe or unnecessary

to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the MB-UAS

to detect

a system fault while in the air and automatically

fly back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre-set wind thresholds; and low bauery levels

. " All flight operations
are global positioning system (GPS) controlled, making the system easy to navigate.
At any point if the operator

is not explicitly commanding

the system
to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but
a variety of sensors including sonar, barometric pressure, temperature, wind speed and others
to ensure stability
so long as wind thresholds
are not exceeded. Also

a flight termination link- to prevent

a 'fly away' or other potentially dangerous situation-

is available

to the operator." 1 See Grant ofExemption
No. 11062toAstraeusAerial (FAA-2014-0352

at pg. 13). 9 • IdU.S Department ofTransportation February 22, 2016 Page 12 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements

for airworthiness certification

of nonnal category rotorcraft.
To the extent that Petitioner's small MB-UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified

in the request for exemption from 14 C .F.R. R. Part 21, Subpart
H, supra. C
. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Petitioner seeks an exemption from the aircraft marking and identification requirements contained

in 14 C.F.R. §§ 91.9(c),
45

. 23(b) and 45

. 27(a). •
14 C.F.R.

§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate

a U.S.-registered civil aircraft unless that aircraft is identified

in accordance with Part 45 of this chapter. •
14 C.F.R.

§ 45.23(b), Markings
of the Aircraft, states: When 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. •
14 C.F.R.

§ 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. In a previous Grant of Exemption,
the FAA detennined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings

in accordance with 14 C.F.R Part 45, Subpart

C if the markings are as large as practicable."

10 Equivalent Level of Safety All MB-UAS flown by Petitioner will bear N-number markings that are as large as practicable

in accordance with 14 C.F.R. Part 45, Subpart
C. 11 1 ° FAA Docket No. FAA-2014-0352 11 S e e, e
. g., FAA Docket No. FAA-2014-0352,

at 14

.U

. S Department

of Transportation February 22,2016 Page 13 D. 14 C.F.R.

§ 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspedions Petitioner seeks an exemption from the maintenance inspection requirements contained

in 14 C.F.R

. § 91.405(a), 91.407(aXl), 91.409(aX2); 91.417(a) and (b). These regulations specify maintenance
and inspection standards

in reference

to 14 C.F.R. Part 43. See, e.g., 14 C.F.R.

§ 91.405(a) (stating that each owner or operator
of an aircraft "[s]hall have the aircraft inspected

as prescribed

in subpart

E of this part and shall between required inspections

. . . have discrepancies repaired
as prescribed

in part 43 of this chapter")

. An exemption from these regulations

is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS platforms

to be operated under this grant of exemption will not have. (Emphasis added) Equivalent Level of Safety An equivalent level of safety will be achieved

or exceeded because maintenance
and inspections will be timely performed

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further,

as required
by Petitioner's Operations Manuals, the PIC will conduct

a pre-flight inspection
of the MB-UAS and all associated equipment

to account for all discrepancies and/or inoperable components

. Maintenance will be performed and verified
to address any conditions potentially affecting safe operation
of the MBUASs and no flights will occur unless, and until, all flight critical components

of the MB-UAS have been found to be airworthy and in a condition safe for operation

. A functional test flight will be conducted following the replacement

of any flight-critical components

. As required by Petitioner's Operations Manuals, the PIC who conducts the functional test flight will make an entry in the MB-UAS aircraft records of the flight. Petitioner's Operations Manual also includes requirements

to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures

& airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Petitioner's Operations Manuals also include procedures

to document and maintain

a record of the MB-UAS's maintenance, preventative maintenance, alterations, status of replacement /overhaul component parts, and the total time in service of the MB-UAS used under this Grant of Exemption.
As a whole, the maintenance
and inspection procedures required

in Petitioner's Operations Manuals ensure that an equivalent

or higher level of safety will be achieved. PILOT-IN-COMMAND

OF THE UAS E. 14 C.F.R.

§ 61.113: Private Pilot Privileges and Limitations Petitioner seeks exemption from 14 CFR

§ 61.113, which restricts private pilot certificate holders from flying aircraft for compensation

or hire, and would also require

a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency

of any PIC matches the airspace

in which the PIC will be operating,

as well as requiring certifications

if the private pilot is carrying passengers

or cargo for hire. In this case, while the MB-UAS will be operated

as part of a commercial operation, they carry neither passengers nor cargo.
In the Grant ofU.S Department ofTransportation February 22, 2016 Page 14 Exemption

to Astraeus Aerial, the FAA detennined that the unique characteristics ofUAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have

a Commercial Pilot Certificate and Class ll Medical Certificate

. 12 The fulfillment
of the additional requirements

for a private pilot to become qualified

as a commercial pilot would not lead to any additional safety benefits when UAS operations
are involved. Equivalent Level of Safety The restrictions Petitioner has placed on its MB-UAS operations meet or exceed the restrictions similarly imposed
on Astraeus Aerial. Petitioner will operate on private property away from persons and property not involved

in the operation

. Petitioner will also obtain an ATO issued COA prior to conducting any operations under this Grant of Exemption.
All operations will be conducted

in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

A NOT AM will also be issued as required by the applicable COA

. In addition

to these flight restrictions, Petitioner will further ensure safe operation
by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining

to all aircraft operators but also in the unique aspects ofMB-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in MB-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are pennitted

to participate

in commercial flights on behalf of Petitioner. The pilot qualification, training, and currency requirements

in the Operations Manuals ensure that Petitioner pilots are competent and proficient

in the MB-UAS they are operating. Petitioner's training and qualification requirements

are consistent with those contained

in prior FAA Section 333 Grants of Exemption, and will provide

a higher level of competency and proficiency
for its pilots and will ensure
at least an equivalent level of safety to the public. OPERATING PARAMETERS

OF THE UAS F. 14 C.F.R.

§ 91.7(a): Civil Aircraft Airworthiness Inasmuch

as there will be no airworthiness certificate issued for the UASs, Petitioner seeks an exemption from 14 C.F.R.

§ 91. 7(a), which requires that
a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption

is required for 14 C.F.R.

§ 91.7(a)
to the extent that the requirements

of Part 21 are waived
or found inapplicable.

13 Accordingly, Petitioner requests that the requirements for§ 91

. 7(a) be treated
in accordance with Section V(A)

, supra. G. 14 C.F.R.

§ 91.9(b)(2): Civil Aircraft Flight Manual
in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352}. 13 See Id. at 13-14, 22.U.S Department

of Transportation February 22, 2016 Page 15 Title 14 C.F.R.

§ 91.9(b) (2) and
§ 91.203(a) and (b) require the operator

to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant

to 14 C.F.R.

§ 91.9(b) (2): (b) No person may operate

a U.S.-registered
civil aircraft

- (2) For which an Airplane
or Rotorcraft Flight Manual

is required by§ 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. Pursuant

to 14 C.F.R.

§ 91

. 203(a) and (b): (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. Given the small size and configuration

of the MB-UAS,

it would be impossible

to keep airworthiness documents and other aircraft manuals on board the MB-UAS because there
is simply no room and the MB-UAS has no cabin or cockpit As a way to comply with the code Petitioner will maintain the documents with the PIC and make them available for inspection

. Equivalent Level of Safety In an FAA Office of Chief Counsel's Opinion dated August

8, 2014, and prepared
by Dean
E
. Griffith, Attorney, AGC-220,

it was acknowledged
that the intent of 14 C

. F

. R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access
to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule

is to ensure the pilot has access to these key documents during flight. Therefore,

an equivalent level of safety will be achieved
by ensuring that the pilot has access to the documents

at the ground control station from which he or she is piloting the UAS. H.
14 C.F.R.

§ 91.103: Preflight Action Petitioner seeks an exemption from 14 C.F.R.

§ 91.103, which requires

a PIC to become familiar with specific information before each flight, including information contained

in the FAAapproved Flight Manual on board the aircraft

. While the PIC will be familiar with all information necessary

to safely conduct the flight, an exemption

is requested

to the extent that an FAAapproved Flight Manual

is required. 14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug.

8 , 2014}; see also Docket No. FAA-2014-0352

at 16-18

.

..U.S Department ofTransportation February 22, 2016 Page 16 Equivalent Level of Safety An equivalent level of safety will be provided
by following the Petitioner

' s Operations Manuals and the Manufactmer's Manual

. The PIC will perfonn

a series of checklists designed

to identify any defects or inoperable components

in accordance with the Petitioner's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required

to review weather, flight requirements, battery charge, landing and takeoff distance, UA perfonnance data, and contingency landing areas-before initiation
of flight. Petitioner's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible

to the PIC at all times while operating the UAS

. I. 14 C.F.R.

§ 91.109(a): Flight Instruction Petitioner seeks an exemption from 14 C.F.R.

§ 91.109(a}, which provides

in pertinent part that "[n]o person may operate

a civil aircraft (except

a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control

is accomplished through the use of a device that communicates with the aircraft via radio communications

. Accordingly,

an exemption will be required for the flight instruction requirements

of 14 C.F.R.

§ 91.109(a). Equivalent Level of Safety Given the size and speed of the UASs that Petitioner intends
to use, an equivalent level of safe training can still be perfonned without dual controls because no pilot or passengers
are aboard the UAS, and as required
by the Petitioner's Operations Manuals,
all persons will be a safe distance away in the event that the UAS experiences
any difficulties during flight instruction. Moreover,

as required
by the Petitioner's Operations Manuals,
all flight training will be conducted

in controlled and sterile environment.

As a whole, the safety procedures provided for in Petitioner

' s Operations Manuals ensure that the proposed UAS operations provide
an equivalent

or higher level of safety than that provided
by the flight instruction regulations. J. 14 C.F.R.

§ 91.119(c): Minimum Safe Altitudes Petitioner requests
an exemption from the minimum safe altitude requirements

of 14 C.F.R.

§ 91.119(

c)
. 15 Section
91

. 119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle,
or structme

in non-congested areas. See 14 C.F.R.

§ 91.119(c). Section 91.119(d) allows for a helicopter

to operate
at less than those minimum altitudes when
it can be operated "without hazard to persons or property
on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed
for helicopters

by the FAA." 15 Relief from§
91

. 119(a) will not be necessary because Petitioner will be able to perfonn an emerg

e ncy landing without undue hazard to persons
or property on the ground
in the event of a failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore
an exemption from

§ 91.119(b) will not be necessary. See e.g

. , Grant of Exemption No. 11157 to Slugwear,

In c., dba Like on a tree Aerial (FAA-2014-0534

at 15)

.U.S Department

of Transportation February 22, 2016 Page 17 An exemption

is required because the proposed MB-UAS operation will normally need to occw below 400 feet AGL. In circumstances where the MB-UAS

is used to inspect

a structure whose height exceeds 400 feet AGL, the MB-UAS will not be operated more than 100 feet above the highest point on the structure, and within 50 feet horizontally

of the structure. Additionally,
due the nature of the proposed operations,
the Pilot and/or Observers(s) may need to be less than 500 feet away from the MB-UAS. Equivalent Level of Safety Compared

to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel with the above noted UASs, any risk associated with these operations

is far less than those which presently exist with conventional aircraft

. An equivalent level of safety will be achieved given the size, weight, and speed of the MB-UASs,

as well as the controlled location where the operations will occur

. In order to avoid any risk to manned aircraft, flight operations will be restricted

to 400 feet AGL or below, or when inspecting

a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet horizontally

of the structure. As set forth in the Operations Manuals, the MB-UAS will be operated

in a restricted area, and all flights will be operated

at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person

is in a position where he or she is shielded from the MB-UAS and any possible debris resulting from its failure

. As required
by the Operations Manuals, flights will be terminated

if a nonparticipating person within 500 feet ofthe MB-UAS leaves

a shielded position. Further, its operations will occur at least 500 feet away from vehicles
or structures unless the property owner/controller timely has granted permission and the PIC has made

a safety assessment
of the risk of operating closer to those objects and, operations near the PIC or Observer will not present an undue hazard per
§ 91.119( a). Adherence

to these restrictions

in Petitioner's Operations Manuals will ensure operations can be conducted without compromising public safety.

16 K. 14 C.F.R.

§ 91.121: Altimeter Settings Petitioner seeks an exemption from 14 C.F.R.

§ 91.121, which requires

a person operating

an aircraft
to maintain cruising altitude or flight level by reference

to an altimeter that is set to the elevation
of the departure airport or barometric pressure. An exemption

is required

to the extent that the UASs do not have

a barometric altimeter, but rather

a GPS altitude read out. 16 See e.g

. , Grant of Exemption No. 11138 to Douglas Trudeau {FAA-2014-0481

at 19)

: "If barriers
or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection

. The operator must also ensure that nonparticipating persons remain under such protection

. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how to immediately cease opemtions, the primary concern

is the safety of those nonparticipating persons

. In addition, the FAA finds that opemtions may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller

of any such vessels, vehicles
or structures gmnts permission
for the opemtion and the PIC makes

a safety assessment

of the risk of opemting closer to those objects and determines that it does not present an undue hazard

. "U.S Department

of Transportation February 22, 2016 Page 18 Equivalent Level of Safety The FAA has stated that an equivalent level of safety to the requirements

of 14 C.F.R. §91.121 can be achieved

in circumstances where: (1) the UASs will be operated below 400 feet AGL or below

17

, (2) within VLOS, (3) where GPS based altitude information

is relayed
in real time to the operator

at a ground-based on-screen display and,

( 4) where prior to each flight,

a zero altitude initiation point
is established
for the PIC to confirm accuracy

of the onboard GPS!

8 The MB-UAS that Petitioner intends
to use for the proposed operations will meet all these operational characteristics. Moreover,

as required
by Petitioner's Operations Manuals, the PIC will be required
to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption,
the MB-UAS Petitioner intends
to use, and the safety mitigation procedures contained

in the Operations Manuals, both ensure that an equivalent level of safety or greater level will be achieved, and
a Grant of Exemption

to the requirements of§ 191.121

is therefore appropriate. L
. 14 C.F.R.

§ 91.15l(a): Fuel Requirements

for Flight in VFR Conditions Petitioner requests
an exemption ftom 14 C.F.R.

§ 91.151(a)'s fuel requirements

for flight in VFR conditions. Section 91.151 states: (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 fly after that for at least 30 minutes;
or {2) At night, to fly after that for at least 45 minutes. Here, the technological limitations
on UAS battery power means that no meaningful flight operations can be conducted while still maintaining

a 30-minute battery reserve. An exemption ftom the fuel requirements of14 C.F

. R. § 91.151(a)

is therefore required

. Moreover,

it is not Petitioner's intention

to fly the MB-UASs

at night. Equivalent Level of Safety In the Grant of Exemption

to VDOS (Exemption
No

. 11112), the FAA determined that an equivalent level of safety to the fuel requirements

for flight in VFR conditions could be achieved by prohibiting
the PIC from beginning

a MB-UAS flight unless (considering wind and forecast weather conditions) there was enough power
to fly to the first intended point oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes.
In reaching this conclusion,
the FAA considered that the UAS batteries for the MB-UAS provide approximately 50 minutes of powered flight (with payload) and provided battery level and battery time 17 If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. 18 See Grant of Exemption No. 11062
to Astraeus Aerial (FAA-2014-0352 at21).U.S Department

of Transportation February 22, 2016 Page 19 remaining

in minutes and seconds

to the PIC.
19 The FAA also considered
the fact the MB-UAS operating manual states: "start every flight with

a fully charged battery
in the aerial vehicle", and that in the event that the MB-UAS should run low on power, the PIC will be alerted and can safely land the- MB-UAS

as soon as possible. Like the VDOS Grant of Exemption, Petitioner's use of the MB-UAS, combined with the requirements

of Petitioner's Operations Manuals, ensure that an equivalent level of safety can be achieved and in fact exceeded. Similarly,

in the Grant of Exemption

to Alan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety to the fuel requirements

for flight in VFR conditions could be achieved
by prohibiting
the PIC from beginning

a flight with the UA unless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. Petitioner will adhere to this limitation for its MB-UAS flights. The MB-UAS includes

a low battery warning system and the amount of battery reserve power remaining

is continuously transmitted

to the PIC via telemetric data feed, which downlinks from the MB-UAS

to a ground-based-on-screen display.

20 As required by Petitioner's Operations Manuals, the PIC will promptly
fly the MB-UAS back to the home launch location
or predetermined abort location where

it may safely land, while still maintaining

a minimum of25% reserve battery power. Petitioner submits that the procedures requiring flights
to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be conducted within

a secure, isolated area, using

a UAS weighing less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent

or higher level of safety to the public
to that provided
by the regulations from which exemption

is sought. VI. DRUG AND ALCOHOL PROGRAM Petitioner will have policies
in place to ensure that no person may participate

in MB-UASs flight operations

if they are under the influence
of alcohol or any drug. VII. PUBLIC INTEREST The public interest will be served by granting Petitioner's Petition for Exemption. Congress has established

a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed

in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act-the FAA Administrator's assessment
of whether certain UAS may operate safely

in the NAS before completion

of the statutorily required rulemaking. 19 • Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382

at 10). 20 • The MB-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, beading, north seeking SJTOW, range to targets, calculated target position, date/time, and sensor heading and orientation relative
to the UAS

.U.S Department

of Transportation February 22, 2016 Page20 The proposed MB-UAS operations

in this Petition for Exemption significantly improves the safety and reduces risk of harm, physical injury and property damage
to the public at large, the property owners from whom permission was granted for use by Petitioner and abutting properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations
and all those who may be in the local vicinity. Traditional methods of inspecting and monitoring potential locations and relevant sites and facilities requires location personnel

to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perfonn elevated work for which the individual

is neither trained nor equipped

to perfonn, which exposes them to unnecessary risk of serious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors

are often unnecessarily exposed

to hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used in the end product. The use of small UASs can eliminate these hazards and ultimately create

a much safer method of performing these types of inspections creating

a safer environment
for the public as well as Petitioner employees. The use of small UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands
of pounds, carrying crew in addition
to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthennore,

in the unlikely event of an accident, Petitioner,s small battery powered MB-UAS presents significantly
less danger
to persons on the ground when compared

to operations

by conventional manned aircraft.

21 As Petitioner's MB-UAS are battery powered, the public will also benefit from

a reduction

in harmful petroleum based emissions associated with conventional aircraft perfonning

in the same functions proposed herein. Air quality will naturally
be improved with the reduction
of fuel powered vehicles. Lastly,
as recognized

by the FAA in prior Section 333 Grants of Exemption

to filmmakers, UASs provide an additional economic tool for the aerial filming notwithstanding

the industry, adding

a greater degree of flexibility, which supplements
the current capabilities offered by manned aircraft.

22 The quality of the finished product

is enhanced and provides

a greater finished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product

is greatly reduced while reducing the difficulty with which the finished product

is created. The demand for the current industrial product

is increasing and will continue

to increase given the enhanced flexibility
of production; therefore, given the lower cost, owner/operators

and others
in the relevant industry will be more inclined

to utilize the services of commercial UAS along with an appropriate licensed PIC's. 21 See Grant ofExemption

No

. 11158 to Team

5 , LLC (FAA-2014-0783

at 12)

: "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition
to other onboard crewmembers,

as necessary. The petitioner's UAS will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals

or property

in the event of an incident
or accident. Risk to an ooboard pilot and crew during an incident
or accident

is eliminated with the use of a UA for the aerial filming operation." 22 See
e

. g., Grant ofExemption

No

. 11178 to Picture Factory, Inc. (FAA-2014-0794

at 18)

.U.S Department

of Transportation February 22,2016 Page21 VIII. PRIVACY All MB·UAS operations will be conducted

in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled·access property with permission from the land owner/controller

or authorized representative. Permission from land owner/controller

or authorized representative
will be obtained for each flight to be conducted. IX. FEDERAL REGISTER SUMMARY Pursuant

to 14 C.F.R. Part 11, the following summary

is provided for publication

in the FEDERAL REGISTER, should

it be determined that publication

is needed: Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: Part 21, Subpart H; Part 27; 45

. 23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151{a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l)

& (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed· wing aircraft, rotorcraft,

or other methods

. X. CONCLUSION Petitioner's Petition for Exemption satisfies the criteria articulated

in Section 333 of the Reform Act of2012 which includes weight; speed; operating capabilities

; proximity

to airports and populated areas; operation within VLOS and nationaJ security. The proposed MB·UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure

to danger while lowering the attendant related costs thereby increasing
the demand for the finished product.
In consideration

of the foregoing, this Petition for Exemption provides the FAA with more than adequate justification

for granting the requested exemptions aJlowing Petitioner

to use small MB·UAS

s in the recorded production

of its product. We thank you for your prompt consideration

of our requested exemptions

. Respectfully Submitted, **~Z. ~-~~**  MBVideoDrone 39734 174th Street E. Palmdale, CA 93591 Phone

: 818.836.4828: Email: ca164kid@gmail.comU.S Department

of Transportation February 22, 2016 Page22 (The following attached items contain proprietary and commercial information exempt from disclosure under the Freedom
of Information Act,
5 U.S.C.

§ 522 et seq., and should be held in a separate file pursuant

to 14 C.F.R.

§ 11.35(b
)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4 . Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8 . Preflight Checklist 9 . Post Flight Checklist 10

. Equipment Checklist 11. UAS Manufacturer's Manuals a . User Manuals b . UAS Maintenance Manuals PETITIONER REQUESTS THAT GOOD CAUSE EXISTS TO EXEMPT ANY PART OF TIDS PETITION FROM BEING PUBLISHED

IN THE FEDERAL REGISTER PUBLIC FORUM BECAUSE THE REQUESTED EXEMPTION WOULD NOT SET A PRECEDENT, AND ANY DELAY IN ACTING ON TIDS PETITION WOULD BE DETRIMENTAL

TO THE PETITIONER.