July 15th, 2015

U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New JerseyAvenue, SE., Washington, DC 20590 Hub Media Company 1835 E 6th Street Suite 5 Tempe, AZ 85281



### VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Be: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Hub Media Company, seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described UnmannedAerial System called in this application the ME System, which includes an Unmanned Aircraft (UA) and ground station-based equipment and crew: THE UNMANNED AIRCRAFT (UA): 

### !R] A lightweight (20 lb gross weight with all on-board equipment), manufactured by DJI, T-600 Inspire 1 that includesthe following equipment in flight; 

## I.RJ An on-board flight computerwith GPS navigation and location abilitythat receives signals for flight controls from a ground-based transmitter/controller; 

## liD An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video; 

### !R] An on-board telemetry system that delivers flight data from the on-board flight computerto the on-board radio transmitter including altitudeAGL, horizontal and vertical speed, compass direction of flight and direction backto its launch site; 

### !R] A 2.4GHz on-board radio transmitterthattransmits live video from the on-board camera plus all the flight datafrom the telemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM: 

## liD A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the 

### UAwhile in the air; 

### !R] A 2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight; 

### !R] A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto a screen for the PIC to view during flight; 

### [ill AVisual Observer (VO) is a person who provides a second pair ofeyesto visuallytrackthe UAwhile in flight.The requested exemption would support an application for a commercial Certificate of Authorization to usethe above described ME System to support Commercial Videography and Photography, Real Estate Video and Photography neveroperating over persons not directly involved with the ME system.
The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than groundbased imageryfor displaying the characteristics of large, complex propertieswith several buildings and large trees. The alternative could be to charter a full-sized helicopterforthis purpose, which has proven more costlythan many potential clients are ableto afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property. Additionally, we requestthat we be allowed to use oursystem to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. The ME System will be operated in the field with both a PIC and a VO in accordancewith FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: a) No flight will be madewith a UAGrossweight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400ftAGL, at an airspeed of no morethan 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be ableto communicate byvoice at all times during a flight operation; d) Operations will be restricted to flights over propertywith the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilotwith a similar UAtype; f) All required permitswill be obtained from state and local government priorto operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; 

### I) Operationswill be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be madewithout a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe for flight (seeAppendixA).

### The PIC and VO will meetthe requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.
We submitthatthe combination ofthe UA's lightweight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (n) listed above, the FAA can have full confidence thatthe operation will have an equivalent or greater level ofsafetythan manned aircraft performing the same mission.
The name and contact information ofthe applicant are: Hub Media Company Ph: 480-223-8113 Email: Stephen@hubmediacompany.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21

................ ..... ...... .... .. Addendum Page 1

- 14 CFR 91.203
.................................Addendum Page 1

- 14 CFR 45.23, 45.29

..... .......... ........... Addendum Page 2

- 14 CFR 91.9

.... .... ............................Addendum Page 2

- 14 CFR 61.113, 61.133

.......................Addendum Page 2 -14 CFR 91.109, 91.119, 91.121

..............Addendum Page3

- 14 CFR 91.151

.................................Addendum Page 3

- 14 CFR Subpart E (91 .401

- 91 .417)

......Addendum Page 3 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1
We are prepared to modify or amend any part ofthis request to satisfythe need for an equivalent level of safety. Please contact us at anytime ifyou require additional information or clarification. We look forward toworking with youroffice.

Step en b arner, Hub Media Com ny

**Addend m**  

### containing Exemption Requests and Equivalent Level of SafetyAppendixA- Flight

**Manual' ~**  

### Appendix B - Owner's Manual for 

### UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Hub Media Company requests an exemption from the following regulations aswell as any additional regulations that maytechnically applyto the operation ofthe ME System:
14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishesthe procedures for the issuance of an airworthiness certificate. While the FAAcontinues to workto develop airworthiness standards for UnmannedAerial Systems, we request an experimental certificate be issued forthe ME System under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operationsto show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit our commercial purpose as well.
The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we proposethat the UAwill be at least as safe, if notsafer, than a conventionally certificated aircraft performing the same mission.
If an experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.
14 CFR 91.203(a) 

### & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, withthe registration number assigned tothe aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew."At a maximum grossweight of 6.5 pounds, the UA is too small to carry documentation, does not have an entrance, and is notcapable ofcarrying passengers orcrew. To obtain an equivalent level of safety and meetthe intent of 91.203, we propose that documents deemed appropriate forthis aircraft bythe 

### FAAwill be co-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the following information plusthe word "EXPERIMENTAL"to satisfythe requirement of 14 CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: OJI Innovations, Inc. 950 E BaselineAve. Ste. 210ApacheJunctionAZ 85119 Models: T-600 Inspire 1
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations providethat each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance tothe cabin, cockpit, or pilot station. The UAdoes not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it bythe FAA.
We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, wherethe PIC, VO and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will providethe aircraft's registration information at the ground station. Finally, wewill display at the ground station a high contrastflag or bannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Sincethe aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observesthe aircraft and chooses to investigate its point oforigin.
14 CFR 91

.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available tothe aircrew while operatingthe aircraft. We request an exemption to this requirement sincethe aircraft is not onlytoo small to carry documentation, the documentationwould not be available to the crew during flight operations.
To obtain an equivalent level of safety and meetthe intent of 91.9, we propose that a current, approved UA Flight Manual (AppendixA) must be availableto the crew at the ground station anytimethe aircraft is in, or preparing for, flight.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation providesthat no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command of an aircraft in connection with any business oremployment if: (1) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require thatthe PIC must either
1. Hold a Sport Pilot Certificate issued bythe FAA, and have logged 25 hours of flight experience in thistype of UA, or
2. Meetthe requirements of 8900.227 para 16(c)(2)(c) "Operationswithout a pilot certificate" in which the PIC is required to complete "FAAprivate pilot ground instruction" and pass "the FAA Private Pilotwritten examination." Since there are currently no means available for the pilot of aUAS to gain the experience in an equivalent category and class in orderto applyfor a commercial pilot's license, we proposeto generate an equivalent level of safety by requiring our pilotsto complete, at a minimum, FAAcommercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Sincethe aircraftcannot carry passengers or property, we feel we meetthe intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.
14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation statesthat "No person mayoperate a civil aircraftthat is being used for flight instruction unlessthat aircraft has fully functioning dual controls." The ME System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operatethe single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel thatthistechnique meetsthe intent 91.109 and provides an equivalent level ofsafety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation statesthat oversparsely populated areasthe aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, orstructure. Sincethe aircraft will be operating at a maximum of 400 feetAGL, we cannot complywith this requirement.
In orderto provide an equivalent level of safetywe will only fly over private propertywith a size of at leasttwo acres with the permission ofthe owner ofthe propertyflown over. The aircraft will not be operated over congested areas orover any open air assembly of persons. The property ownerwill be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraftwill be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons orproperty on the surface.
Therefore we maintain that due to the small size ofthe UA, the hazardto persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft.
The UAwill always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above thetakeoff point is transmitted via radio from the UAon-board computerto the display screen held bythe PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation providesthat no person may begin a flight in an airplane under day-VFR conditions unlessthere is enough fuel to fly tothe first point of intended landing and to fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delaysto landing. The UAis battery operated andthe maximum duration offlight from a single battery charge is 18 minuteswith a 20% reserve. Sincethe aircraft will neverfly more than 314 NM from the point of intended landing, a full battery charge atlaunch will ensurethatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption tothe word "fuel" and askfor an equivalent interpretation with the word "energy".
14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation providesthatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.
It is our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service."As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensurethatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenancewill be performed bythe manufacturer ortheir designated repair facility. The PIC will documentwork performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy providesthat both the PIC and VO must have a valid FAAsecond-class medical certificate issued under part 67 in orderto perform as a pilot orobserver. The UAmaximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitatedwhile the aircraft is in flight, the UAwill return autonomouslytothe site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We proposethatthe minimum medical requirements forthe PIC and VO bevision corrected to 20/20 and a valid, state issued driver's license. The 20/20vision requirement will ensurethatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle.APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS a) No flight will be madewith a UA Grossweight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no more than 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be ableto communicateverbally at all times during a flight operation; d) Operationswill be restricted to flights over property with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilotwith a similar UAtype; f) All required permitswill be obtained from state and local government priorto operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operationswill 

### be restricted to dayonly and weather conditions equivalent to VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be madewithout a successful Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UA is in a condition safe for flight. PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected tothe aircraft. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Homefeature is activated and will bring the UAV backto the PIC.