1

August 31, 2015 U.S. Department of Transportation Document Management Sy stem 1200 New Jersey

Ave., SE West Building Ground Floor, Room W12

- 140 Washington, D.C. 20590 Concerning : Unmanned Aircraft Sy stems (UAS) Petition for Exemption Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 61.23(a) ; 61.101(e)(4) and (5); 61.113(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b).

Ple ase Address all communications with respect to this Petition to: Jason Thomas McGarraugh Ghost Tracs Ventures LLC 1916 Trammel Drive Nolensville TN. 37135 Phone: 615

- 719

- 2972 Fax: 561

- 427

- 7255 Email: Jason@Ghos tTracs.com2 **Petition for Exemption Summary** Dear Sir or Madam, Pursuant to Section 33 of the FAA Modernization and Reform Act of 2012, and 14 CFR Part 11, Ghost Tracs Venture s L .L .C., an operator of an Unmanned Aircraft Sy stem (UAS) hereb y applies for an exemption from the listed Federal Aviation Regulations (FAR’s) to allow co mmercial operation of its UAS. Ghost Tracs Ventures L.L.C. is eligible for an exemption for film/television production, and aerial videograph y for TV, inte rnet commercials, marketing, for the motion picture and television industry

for scripted closed se t filming , and search and rescue

. **Summary:** Ty pe of UAS to be flown: DJIInspire 1 using the DJIA2 Flight Controller (Previou sly granted in Exemption #11252), and the DJ I Inspire 1 airframe configuration (Previously granted in Exemption #11303 & # 11279 ). The operations will be for aerial videograph y, and photography for the motion picture and television industry

(Exemption #11279), and for search and rescue operation (Exemption #12654). DJIInspire o Aircraft Ty pe: Multi

- Rotor o Construction: Carbon Fiber, plastic, aluminum o Pro pulsion: Electric (4) Brushless, 3 phase, AC Motors. o Onb o ard Electronics: A2 Flight Controller, manual control sy stem, flight control sy stem optics, still and video imager, 2.4/5.8 Ghz L ightbridge o Launch T ype: VTOL o Landing T yp e: VTOL o Launch Speed: 15 MPH Vertical o Speed Envelope: 35 MPH Cruise, 0 MPH Stall o Duration of Flight: 15 Minutes o Aircraft Weight: 3.3 lbs

. / (Empty)
**Ghost Tracs LLCs request for exemption w**  **ould be a Benefit to the Public:** The DJ I Inspire 1 is designed to collect its imagery utilizing VTOL capabilities ; where a fixed wing aircraft, or UA, could have difficulties in either take off or landing. The DJ I Inspire 1 is equipped with a Return

- To

- L aunch area (RTH) feature, which can be activated in the event of an emergency with the PIC, or UAS . The DJ I Inspire 1 does not use internal combustion motors for propulsion , and does not carry an y flammable liquids for oper ation. Risk to the public is further reduced by the DJ I Inspire 1's ability to stay3

aloft while moving slowly , or to hover in place, unlike a fixed

- wing aircraft, or UA , which must continue lateral motion during flight. The Benefit to the P ublic is unquestionab le. The use of manned aircraft is in many instances much more expensive, and much more dangerous, than the operations pro posed herein. Therefore , the operations presented in this summary are at least an equivalent level of safety

under 14 CFR part 11.

**E xtent of Relief:**  Regulations from which the exemption is requested:

o 14 C.F.R. § 61.23(a) o 14 C.F.R. § 61.101 o 14 C.F.R. § 61.113(a) o 14 C.F.R. § 61.315 o 14 C.F.R. § 91.7(a) o 14 C.F.R. § 91.119 o 14 C.F.R. § 91.121 o 14 C.F.R. § 91.151(a)(1) o 14 C.F.R. § 91.405(a) o 14 C.F.R. § 91.407(a)(1) o 14 C.F.R. § 91.409(a)(1) & (2) o 14 C.F.R. § 91.417(a) & (b) This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law directs the Secretary

of Transportation to consider whether certain unmanned aircraft sy stems may

operate safely

in the national airspace sy stem (NAS) before completion of the rulemaking required under Section 332 of the FAA Modernization and Reform Act. In making this determination, the Secretary is required to determine which ty pes of UA do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: (Exemption #12657)

o The UAS’s size, weight, spee d, and operational capability ; o Operation of the UAS in close proximity to airports, and populated areas, and o Operation of the UAS within visual line of sight of the operator (VLOS).4

**Aircraft Equivalent Level of Safety** Ghost Tracs LLC proposes that the exemption requested herein applies to civil aircraft that have the characteristics , and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety t o operations under the current regulatory structure. Ghost Tracs LLC agrees to be bound to FAA regulations when conducting commercial UA S operations. The list of limitations and conditions include the following: 1. Operations authorized by this grant of exemption are limited to the DJ I Inspire 1 UAS when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion picture and television filmin g are permitted. 3. Operations for the purpose of Search and Rescue are permitted. 4. Operations for the purpose of aerial photography, and videograph y of real estate, sporting events, concerts, and other events are permitted as long as commercial UAS se rvices were requested of Ghost Tracs LLC, and legal permission granted by the requestee; not superseding an y FAA conditions, and limitations connected to this exemption. 5 . The UA S may

not be operated at a speed exceeding 87 knots (100 miles per hour). T he exemption holder may

use either groundspeed , or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA S be operated at airspeeds greater than the maximum UA S operating airspeed recommended by the aircraft manufacturer. 6 . The UA S must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 7 . The UA S must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate or U.S. driver’s license. 8 . All operations must utilize a visual observer (VO). The UA S must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The VO and PI C must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO.5

9 . This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and re vised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10 . Any UAS that has undergone maintenance or alterations that affect the UAS operation o r flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may onl y be conducted b y a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 11 . The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a c ondition for safe operation 12 . Prior to each flight, the PI C must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 13 . The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 14. The UAS operated under this exemption must comply with all manufacturer safety b ulletins. 15 . Under this grant of exemption, a PI C must hold either an airline transport, commercial, 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 issue d by a state, the District of Colombia, Puerto Rico, a territory , a possession, or the Federal6

government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certif icate. 16 . The operator may

not permit any

PIC to operate unless the PI C demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PI Cs and VOs (training , proficiency , and experience

- building) and determining the PIC’s ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may

onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 17 . 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. 18 . The UA S may

not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA published ae ronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 19 . The UA S 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 PI C. 20. If the UAS loses communications , or loses its GPS signal, the UA S must return t o a predetermined location within the private , or controlled

- access property
. 21. The PI C must abort the flight in the event of unpredicted obstacles or emergencies. 22. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA S to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended b y the manufacturer if greate r. 23. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may

appl y for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.7

24 . All aircraft operated in accordance with this exemption must 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 must be as large as practicable. 25 . Documents used b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 26 . The UA S must remain clear and give way to all manned aviation operations an d activities at all times. 27. The UAS may

not be operated b y the PIC from any moving device or vehicle. 28. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barrie rs or structures are present that sufficiently protect nonparticipating persons from the UA S 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 nonpart icipating persons leave such protection and are within 500 feet of the UA S , flight operations must cease immediatel y in a manner ensuring the safety

of nonparticipating persons; and b. The owner/controller of an y vessels, vehicles or structures has grante d permission for operating closer to those objects and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 29. The PI C, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 30 . All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property own er/controller or authorized representative will be obtained for each flight to be conducted. 31 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be rep orted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.8

** For the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitatio ns apply. 32 . The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 33 . At least 3 day s before aerial filming, the operator of the UAS affected by this exemption must submit a written P lan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

o Dates and times for all flights; o Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; o Name and phone number of the person responsible for the on

- scene operation of the UAS; o Make, model, and serial or N

-Number of UAS to be used; o Name and certificate number of UAS PI Cs involved in the aerial filming; o A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of tho se who gave permission must be made available to the inspector upon request; o Signature of exemption holder or representative; and o A description of the flight activity , including maps or diagrams of any area, city , town, county , and/or state over which fi lming will be conducted and the altitudes essential to accomplish the operation. 34. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

**STATUTORY CRITERIA PROVIDED IN SECTION 333** The Federal Aviation Act (49 U.S.C.§ 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate and under the restrictions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. Since the UA S fully

loaded weighs no more than 55 lbs. and is operated without an onboard pilot, there is no ability or place to carry

certification and registration documents9

or to display

them on the unmanned aircraft. An equivalent level of safety will be achieved b y keeping these documents at the ground control point where the pilot flying the UA S will have immediate access to them. Given the size of the unmanned aircraft, the FAA registration number will be displayed on the airframe in as large a font as possible.

**14 C.F.R. § 61.23(a) & (c): MEDICAL CERTIFICATES** Exemption #11221, # 11284, and man y others have provide d that a U.S. driver’s license could be used in lieu of the medical certificate.

**14 C.F.R. § 61.101(e)(4) & (5): RECREATIONAL PILOT PRIVILEGES AND L**  **IMITATIONS & 14 C.F.R. § 61.315(a): SPORT PILOT LIMITATIONS** Exemption # 11221, # 11284, and man y others have provided that the “PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.” Likewise, Ghost Trac s LLC is also performing commercial UAS work and is asking for the same restrictions, which have been previously deemed to provide an equivalent level of safety as the burdensome regulations.

**14 C.F.R. § 61.113 (a): PRIVATE PILOT PRIVILEGES AND LIMITATIO NS:**  **PILOT IN COMMAND.** Sub

- sections 61.113(a) limit private pilots to non

- commercial operations. Because the UAS will not carry

a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PI C operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely

controlled with no living thing on b oard.

**14 C.F.R. §**  **91.7(a): CIVIL AIRCRAFT AIRWORTHINESS.** The DJ I Inspire 1 uses the DJ I A2 flight controller that has been pre viously approved in Exemption # 11252. The DJIInspire 1 aircraft configuration has been granted in other exemptions such as Exemption #11303 & #11279 . Therefore, this aircraft should not be required to have an airworthiness certificate based upon the FAA’s previous determinations.10

**14 C.F.R. § 91.119: MINIMUM SAFE ALTITUDES** Section 91.119 establishes safe altitudes f or operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters b y the FAA. Because of the lack of flammable fuel, any risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between th ese small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. § 91.121: ALTIMETER SETTINGS** This regulation requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. The oper ator, pursuant to the operating manuals, will achieve an equivalent level of safety .
**14 C.F.R. § 91.151(a): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS**  Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fl y to the first point of intended landing, and, assuming normal cruis ing speed

- (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." Ghost Tracs LLC. believes that an equivalent level of safety can be achieved by restricting operations to “be completed within 30 minutes flight time or with 25% battery power remaining, which ever occurs first.” (Exemption # 11062, at page 27 ) . If, however, the above limitations are not satisfactory to the Administrator, the petitioner is prepared, in the name of expedienc y, to accept limiting the PI C from beginning a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) “there is enough available power for the UA to conduct the intended operation and to operate after that f

or at least five minutes or with the reserve power recommended by the manufa cturer if greater.” (Exemption # 11284, page 5 )11

**14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): MAINTENANCE INSPECTIONS**  These regulations require th an an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspection, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 appl y to only aircraft with an airworthiness certificate, these sections will not apply to Ghost Tracs LLC . An equivalent lev el of safety will be achieved because this UAS is very limited in size , and will carry a small payload , and operate only in restricted areas for limited periods of time. Moreover, the operator is the person most familiar with the aircraft and best suited t o maintain the aircraft in an airworth y condition to provide the equivalent level o f safety. Lastl y, Ghost Tracs LLC. will operate in accordance with the manufactures manual which will provi de an equivalent level of safety .
**Other Exemptions** Petitioner req

uests relief from any

other Federal Aviation Regulation that the FAA deems applicable to and preclusive of the proposed UAS Search & Rescue Operations in the absence of such an exemption.

**Request for Blanket COA** Petitioner hereb y requests a blanket, nationwide Certificate of Waiver or Authorization for airspace use within Class G airspace, at or below 400 feet. The need for a blanket COA for Petitioners proposed operation (or an exemption from the need to obtain o ne) is self

- evident. Unlike other pre

- planned small UAS operations, search and rescue requires an operational response on little notice, and minutes can literally make the difference between life and death. FMRA Section 333 directly contemplates that a cer tificate of waiver or authorization is not necessaril y required for the operation of civil UAS. It provides that in making a Section 333 determination concerning operation of unmanned aircraft s ys tems, “the Secretary shall determine . . . .whether a certif icate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraf t sy stems.” FMRA Section 333(b) By

using the word “whether,” Congress specif ically contemplated that a COA would not necessarily be required for an y civil operation. Therefore, the FAA has the authority

to either exempt Petitioner from the need to obtain a COA, or to issue to Ghost Tracs LLC. a standing blanket COA that is suited for the contemplated search and rescue operations.12

Ghost Tracs LLC. respectfully submits that a standing COA granted for search and rescue operations is overwhelmingl y in the public interest because it will enable life

- saving operations to commence sooner , and reduce the administrative burden on the FAA itself. The FAA has recentl y indicated that holders of UAS exemptions under Section 333 are now granted a “blanket” COA for any operation up to 200 feet AGL. See March 20, 2015 Memorandum from Elizabeth L

. Ray to Terry Biggio, “Small Unmanned Aircraft Sy stems Operations in the National Airspace S ys tem.” However, this streamlined (or so

called “blanket”) COA apparentl y still requires the operator to issue a Notice to Airmen (NOTAM) “at least 24 hours prior t o the proposed operation.” In man y instances Ghost Tracs LLC. expects to be called upon with less than 24 hours’ notice. Ghost Tracs LLC. requests that its blanket COA issued in connection with the requested exempt ion require only that Ghost Tracs LLC. iss ue a NOTAM “as far in advance of operations as practicable,” with no specific minimum notice provision. Additionally , Ghost Tracs :LLC. FSOP and equipment are optimized for search and rescue from an operational altitude of just below 400 feet AGL. The 200 feet AGL in the “blanket” COA is too low an altitude for these operations. Without a streamlined COA at an altitude higher than 200 feet, Ghost Tracs LLC. will be waiting day s (or weeks) for a civil COA just to be able to operate at a modestly higher alti tude, rendering the exemption po tentially

unworkable. Ghost Tracs LLC. requests a streamlined COA for the highest altitude the FAA will permit, ideally 400 feet AGL. An equivalent level of safety is established for these blanket COA parameters because, currentl y, operations of this kind are permitted b y FAA , by recreational model aircraft operators without an y C OA or NOTAM requ irements. Moreover, Ghost Tracs LLC. operations are subject to NIMS protocols and coordination with Incident Command and other firs t responders, who will be aware of air traffic in the area. Therefore, unlike commercial UAS operations undertaken for industrial purposes, added layers of safety exist. All of these factors support the issuance of a streamlined or “blanket” COA for Ghost Tracs LLC. in Class G airspace up to 400 feet above ground level, or a determination pursuant to FMRA Section 333(b) that a COA is not required for Ghost Tracs LLC. s earch an d r escue operations

.

**Conclusion :**  The operation of Ghost Tracs LLC. using a small UAS, weighing less than 55 lbs., conducted under the proposed restrictions outlined above, will provide an equivalent level of safety

supporting the grant of the exemptions requested herein.13

**A Summary That Can Be Published In The Federal Register**  **:** Petitioner : Ghost Tracs LLC. seeks an exemption for the operation of unmanned aircraft sy stems (UAS) for purposes of aerial photograph y, videograph y, and search and rescue operations . The benefit to the public interest of such an exemption is unquestionable. The use of manned aircraft is in many instances much more expensive, and much more dangerous, than the operations proposed herein. Thus, the operations are of enormous public benefit. Regulations from which the exemption is requested:

o 14 C.F .R. § 61.23(a) o 14 C.F.R. § 61.101 o 14 C.F.R. § 61.113(a) o 14 C.F.R. § 61.315 o 14 C.F.R. § 91.7(a) o 14 C.F.R. § 91.119 o 14 C.F.R. § 91.121 o 14 C.F.R. § 91.151(a)(1) o 14 C.F.R. § 91.405(a) o 14 C.F.R. § 91.407(a)(1) o 14 C.F.R. § 91.409(a)(1) & (2) o 14 C.F.R. § 91.417 (a) & (b)
Based upon the foregoing, Ghost Tracs LLC. requests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of the Federal Aviation Act as requested herein to allow commercial operations of the DJ I Inspire 1 within the continental United States and its territories.
Respectfully

Submitted, Jason Thomas McGarraugh Ghost Tracs Ventures LLC 1916 Trammel Drive Nolensville TN. 37135 Phone: 615

- 719

- 2972 Fax: 561

- 427

- 7255 Email: Jason@GhostTracs.com