U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. S.E. Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and

Reform Act of 2012 from 14 C.F.R. Part 21; 14 C.F.R. 43.7; 14 C.F.R. 43.11 ; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 61.113; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151;

14 C.F.R. 9 1.203(a) & (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 91.409; and 14 C.F.R. 91.417.

Dear Sir or Madam:

550 Productions, LLC, a Colorado Limited Liability Company, seeks an exemption

to certain Federal Aviation Regulations (FARs) pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (the Reform Act) and Part 11 of Title

14 of the C.F.R. 550 Productions , LLC is an organization providing aerial photography and cinematography services utilizing Sma ll Unmanned Aircraft Systems (sUASs) in the creation of real estate listing advertisement materials mainly for large estates in rural areas and for commercial film productions

. Additionally, 550 Productions occasionally engages in a variety of aerial surve ying activities including orthomosaic mapping which aids various businesses in project management by helping to create survey grade imagery which can be used for extracting volumetric data and conducting other geospatial analytics.

Approval of exemptions for 550 Productions , LLC will allow commercial sUAS operations in primarily remote, rural areas across Colorado for real estate photography and cinematography, and

– to a lesser extent

– in filmmaking productions and other environments where a conventional aircraft wo uld be cumbersome at best, and pose severe safety risks at worst. 550 Productions , LLC intends to employ a pilot who will act as the Pilot

- in

- Charge (PIC) having, at a minimum, a private pilot certificate and 3rd

- class medical certificate. This pilot

will receive flight instruction specific to the aircraft used by 550 Productions

, LLC

from Mr. Joshua Keffer , who has over 500 hours of flight time with various

sUASs.

This exemption request should be granted because the use of the aircraft utilized by

550 Pro ductions , LLC under the conditions and limitat ions proposed below willmeet or exceed an equivalent level of safety as Congress has intended. 550

Productions LLC’s sUAS, the DJI Inspire 1, weighs just 6.5 lbs. The lightweight aircraft covered by this exemp tion request are far safer than the alternative: manned aircraft weighing thousands of pounds and carrying hundreds of pounds of combustible fuel. Similar sUAS operations have already been approved in Exemption No. 11138 , Douglas Trudeau, Realtor and Exemp tion 11136, Advanced

Aviation Solutions

. In all cases, flights undertaken by employees of 550

Productions , LLC will be conducted with safety as the paramount goal. Al l flights will be at low altitudes and operators shall use pre

- programmed, GPS guided flight patterns whenever possible. No flights shall begin unless the aircraft has first acquired an adequate GPS signal for tracking purposes from the ground station and

GPS

- aided flight.

If you have need of additional information for the assessment of the exe mption request please do not hesitate to contact us at 719

- 235

- 2220 or josh@550productions.com.

Thank you,

Joshua L. Keffer

Owner/President of 550 Productions LLCI. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is prov ided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. Part 21; 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 61.113; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 91.409; and 14 C.F.R. 91.417. Approval of these exemptions for 550 Productions , LLC will allow commercial operations of sUASs for the purpose of producing real estate marketing materials, and secondarily for co mmercial filmmaking and aerial survey and inspection activities. The exemption should be granted because the operations proposed by 550 Productions , LLC, using unmanned sUASs weighing no more than 10 lbs., conducted according to the conditions and limitati ons discussed below will provide a level of safety exceeding that of traditional aerial operations utilizing manned aircraft. Each of the factors identified by the Congress in approving this exemption process under Section 333

– size, weight, speed,

operat ional capability, proximity to airports, proximity to populated areas, and operation within visual line of light

– supports approval of the exemptions sought by 550 Productions , LLC. Specifically, the sUASs weigh no more 10 lbs., flight

will be restricted to class G airspace at altitudes no greater than 400 feet AGL and at speeds no greater than 35 knots, and no flights will be conducted unless the aircraft has first acquired an adequate GPS signal to enable GPS

- aided flight.

II. Contact Information

550 Pro ductions , LLC

3530 Birnamwood Dr. Colorado Springs, CO 80920

Tel: 719

- 235

- 2220

E

- Mail: jonathan.bracewell@gmail.com

III. 550 Productions , LLC’s Operations

A. The sUAS550 Productions, LLC currently operates one model of aircraft : the DJI Inspire 1. The market for aerial imagery is rapidly evolvi ng, and there a re market forces which pressure vendors to constantly upgrade equipment. These facts, combined with the length of time it takes to receive a grant of exemption, may make it difficult to operate in the market with current equipment: by the time the exemptio n for the specific aircraft is granted, those aircraft may very likely be outdated and/or obsolete. Therefore, 550 Productions , LLC requests that any exemption granted extend not only to aircraft currently owned by 550 Productions

, LLC, but also to any fut ure sUASs owned by 550 Productions, LLC that meet the following criteria:

1. The sUAS weighs no more than 10 lbs. at takeoff.

2. The sUAS has GPS capability which aids its flight.

or

1. The sUAS has already been approved for commercial use by a publ ished FAA Grant of Exemption. E.g. the SenseFly eBee permitted in Exemption No. 11136,

Advanced Aviation Solutions.

Without abandoning the above request, 550 Productions , LLC explicitly requests the exemp tion allow the operation of the DJI Inspire 1. Th e sUAS is a battery

operated multirotor aircraft weighing less than 10 lbs.

Respectively, the sUAS employed by 550 Productions , LLC have the following specifications:

Airframe: DJI Inspire 1 Flight Control System: The built

- in flight contro l system

con tains the MC (main controller), GPS + GLONASS processor, IMU (inertial measurement unit) and compass. The MC is the brains of the system, receiving thousands of bits of data each second and translating that data for optimal flight stability. The GPS proces sor now includes the capability to receive signals from

the Russian

- built GLONASS satellites, which improves positioning accuracy and quicker satellite acquisition. The IMU contains a 6

- axis gyroscope as well as an

accelerometer. Max takeoff weight: 6.5 l bs. Max flight speed: 43 knots Max ascent/descent speed: 16.4 ft/sec; 13.1 ft/sec Battery type: 6S LiPo, 22.2V, 4500mAhThe aircraft has distinct failsafe capabilities. The Inspire 1 continuously estimates the amount of battery power required to fly t he aircraft back to the Home Point. Once this level of battery power is reached, a message will appear within the flight control program alerting the operator. 550 Productions , LLC employees will always attempt to return the aircraft to the Home Point when this message appears. If no action is taken, the aircraft will automatically fly up to a pre

- set altitude, then fly to the Home Point and land (this is the return

- to

- home function or RTH). Additionally, the flight software will automatically conduct an RT H if the signal from the remote controller is lost for more than three seconds. Before each flight, the operator will inspect the area where the flight will take place and note the tallest obstruction. The operator will then set the failsafe altitude to a height greater than the tallest object in the area.

The sUASs has a limited range due to the physical limitations of the transmissions from the remote controller. In field conditions, this limited range is generally not greater than 1,000

- 1,200 meters or roughly 3,300

- 3,900 feet.

The sUAS has the capability for a maximum altitude to be set prior to each flight. This is a separate setting from the maximum altitudes which are unchangeable and are set by the manufacturer from the factory. Using GPS data to determine altitude,

the sUAS will not violate either of these altitude limit parameters.

Please refer to the respective user manuals for the aircraft which are attac hed to this petition as Exhibit 1 for additional information.

B. Flight Conditions

T he sUAS will be flown in airspace no greater than 400 feet above ground level (“AGL”) and under controlled conditions in predominantly rural areas. When not operating in a rural environment, such as a closed filming set or location, th e operations will be conducted with s trict personnel access controls as needed to

ensure the safet y of all personnel in the area. All personnel in the area will be informed of the sUAS flight and will be given proper safety instructions prior to

take off. The majority of flights will occur in rural areas of Colorado over real estate properties that are typically greater than 250 acres in size. 550 Pr oductions

, LLC will work with the local FSDOs to ensure each operation is conducted in a way that avoids conflict with other ongoing operations in the NAS. The aircraft will be flown only in class G airspace during VMC, visual meteorologicalconditions: no less than 500 feet below and no less than 2,000 feet horizontally from a cloud and with visibility at least three statute miles from the PIC.

C. Flight Operations

550 Productions , LLC will require every operator to fly the aircraft within visual

line of sight (VLOS) of the operator as well as a second individual previously designated as the visual observer (VO). Flights shall always be conducted in class G airspace at or below 400 feet AGL and at speeds no g reater than 35 knots. The

PIC shall have at a minimum a private pilot certification as well as a third class medical certificate. Each PIC will undergo hands

- on training with the sUASs and achieve a minimum of 10 flight hours before flying for a client of 550 Productions

, LLC.

All operations will c omply fully with applicable state and local laws. The majority of flights will take place over real property exceeding 250 acres. The PIC will coordinate with the local FSDO when planning operations. The PIC will consult

aeronautical charts and review the relevant weather data prior to each operation, and brief other members of the flight crew on his findings before each operation begins. During the planning phase of each operation the flight crew will ensure that the sUAS has the most recent firmware updat es from the manufacturer so that the sUAS will operate using the most up

- to

- date controls and parameters from the manufacturer. The flight crew shall perform this firmware check no more than one week prior to the scheduled flight.

The flight crew will ut ilize various measures to ensure that non

- participating persons do not accidentally enter the flight area. Such measures may include locking the gate to a ranch prior to the flight, or setting orange cones and warning signs around the area where the flight will occur. The flight crew will always work

with property owner s and/or the film producers and crew to ensure unnecessary personnel are not present during the flight.

Before conducting any operations, the flight crew will inspect the components of

the sUAS for any visible indications of damage. The crew will then turn on the

sUAS and allow it to conduct its full self

- diagnostic test which each sUAS performs upon startup. The flight crew will ensure that the sUAS has acquired its GPS signal and then cali brate the onboard compass. No flights (including the test flight) shall take place unless the sUAS has acquired a GPS signal the compass has been calibrated properly in accordance with the respective sUAS user manual, and the sUAS has passed its self

- diagn ostic test. Next, the PIC will verify that thealtitude limit in the flight control program has been set to 400 feet AGL. The crew will then initiate a brief test flight, bringing the sUAS to 15 feet AGL in order to check the flight controls and camera ope ration. After performing as many maneuvers as the PIC finds necessary, but never exceeding more than 100 ft horizontally from the ground station, the test flight shall conclude and the PIC shall bring the aircraft back to its Home Point. Every Home Point s hall be prominently marked with orange cones or white engineering tape or some other method of marking which provides a similar level of visibility.

The VO shall make use of a separate video monitor to assist in maintaining visual

contact with the sUAS. T his monitor will display images received wirelessly from

the camera onboard the sUAS.

At any time during the flight, should the aircraft lose connection with the remote control, the flight control system failsafe will be activated automatically, and the aircraft will make a controlled descent either in place or to the Home Point as dictated by the aircraft’s capabilities and weather conditions.

In addition to these safeguards, DJI has programmed into the firmware of each

sUAS certain “no

- fly zones” whic h will prevent flights in re stricted airspace. See

Exhibit 1 on page 46

- 48. Any DJI sUAS will not start its motors in these pre

programmed no

- fly zones, or if it enters this space during an ongoing flight, the sUAS will automatically descend to an altitud e outside of the no

- fly zone, or commence landing.

During flights, the PIC and the VO will stand next to each other in constant voice contact at the ground station. If weather conditions suddenly make continued flight unsafe, the PIC will fly the sUAS to a safe altitude above all local obstructions and bring the sUAS back to the Home Point or alternatively use the camera to locate a safe secondary landing area if the weather conditions are such that returning to the

Home Point is either not feasible or no t safe.

Flights will be limited to 75% of the battery life of the sUAS. This information is indicated on the sUAS itself by flashing lights and also on the remote controller’s

video screen.

When performing aerial survey operations by pre

- programmed, au tomated flight patterns, the PIC will maintain positive control of the remote controller in the event a manual override in necessary. All procedures will remain the same for this type of operation with the following exceptions:1. The flight crew shall t horoug hly inspect the area to be surveyed and note all

obstructions.

2. The PIC shall set the automated flight altitude at a level certain to clear the obstacles observed by the flight crew.

3. The PIC shall coordinate with the site foreman, or a person of s imilar responsibility to determine the best time of day during which to conduct the operation.

IV. Aircraft and Equivalent Level of Safety

550 Productions , LLC proposes that the exemption requested herein apply to any

civil aircraft that have the characte ristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure.

These limitations and conditions to which 550 Productions , L LC agrees to be bound when conducting commercial operations under an FAA issued

- exemption

include:

1. The sUAS will weigh less than 10 lbs. The DJI Inspire 1 weighs 6.5 lbs.

2. Flights will be operated within VLOS of the PIC and VO and only during VMC

.

3. Maximum total flight time for each flight will be 75% of battery life. Flights will be terminated once the battery reaches a 25% level. This information is transmitted to the remote controller as well as indicated by flashing lights on the sUAS itse lf.

4. The sUAS will remain clear and yield the right of way to all other manned operations and activities at all times.

5. Flights will be conducted at an altitude not to exceed 400 feet AGL.

6. Minimum crew for each operation will consist of the PIC and VO.

7. A briefing from the PIC will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for thi s briefing.8. The operator will obtain a FAA Civil COA prior to conducting any operations under this grant of exemption.

9. The operator will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to th e operation.

10. The PIC and VO will at all times be able to communicate by voice and be stationed next to each other at the ground station.

11. Written and/or oral permission from the landowner or authorized agent, of the

land over which the sUAS is flying will be obtained prior to each operation.

12. All required permissions and permits will be obtained from territorial, state, county and/or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

13. The sUAS will have the capability to automatically abort a flight in case of poor signal communication with the PIC’s remote controller.

14. No operations shall take place within 5 nautical miles of an airport reference as noted on a FAA published a eronautical chart.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and pop ulated areas and operation within visual line of light and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUASs pursuant to the conditions and operations d escribed above.

V. Public Interest and Safety

Use of the sUASs will increase ground safety by eliminating the need to have a manned aircraft take the videos or photographs. As recognized in other exemptions, (e. g. Exem ption Nos. 11136 & 11138 ), sUAS flight offers several advantages over manned aircraft. Manned aircraft often weigh in excess of 5,000 lbs. and carry more than 100 gallons of highly combustible fuel. The sUASs in this petition carry no combustible fuel and only weigh a maximum of 6.5 lbs., greatly reducing the potential forces at work in the case of an incident. Furthermore, there

is much less risk of harm to human life since the sUASs have no crew onboard.Environmental factors weigh heavily in t he public interest and in favor of granting the exemption. Other than real estate marketing videos and commercial video production

, 550 Productions , LLC engages in environmental compliance operations, including, but not limited to, mapping, oil pipeline remote insp ection and smokestack inspection. With respect to visual insp ection of smokestacks, flying a sUAS allows the inspector to remain safely on the ground reviewing images and video instead of having to be hoisted into the air hundreds of feet in

order to condu ct the inspection. Use of the sUASs makes these operations not just safer, but more efficient so that companies can achieve compliance in a less costly manner. Additionally, flying an sUAS has a negligible environmental impact compared to manned aircraft w hich burn hundreds of pounds of hydrocarbon

based fuels during flight.

VI. Regulations from Which Exemption Is Requested

A. 14 C.F.R. Part 21

- Certification Procedures for Products and Parts

550 Productions , LLC requests an exemption from 14 C.F.R. Part 21, and particularly Part 21(h). Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. The FAA has held in Exemption No. 11136, Advanced Aviation Solutions, that exemption from Part 21 was not necessary because of the diminutive size of the aircraft, and lack of personnel on board the aircraft.

Equivalent level of safety: An equivalent level of safety with airworthiness

c ertification can be achieved by the use of sUASs and the conditions and limitations imposed on operations which have been proposed in this petition. As the FAA pointed out in Exemption No. 11136, “Manned aircraft are at risk of fuel spillage and fire in th e event of an incident or accident. The UA carries no fuel and

therefore the risk of fire . . . due t o fuel spillage is eliminated.” Additionally, just like the sUAS in that grant of exemption, the sUASs under this petition have GPS guided capabilities whi ch greatly reduce the likelihood of accidents. As the FAA observed, “These safety features ensure that these operations will not adversely impact safety compared to a manned aircraft performing a similar operation . . . .” In addition to these safety featu res, the sUAS operated by 550 Productions , LLC weigh less than 10 lbs., fly no faster than 43 knots, and can fly no more than 1,200m from the remote controller in ordinary field conditions.B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airfr ames, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenan ce, rebuilding, or alteration.

550 Productions , LLC requests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service.

Equivalent level of safety: 550 Productions , LLC has years of ex perience among its employees in repairing and modifying recreational aircraft such as those included in this petition. The nature of the sUASs is that of a model aircraft. When

necessary, 550 Productions , LLC and its employees will conduct inspections and maintenance based on maintenance guidelines provided by the manufacturer of the

sUAS , DJI. All modifications and repairs will be tested for proper functionality before flying over property not belonging to 550 Productions , LLC or its agents.

Because of the simple nature of these aircraft which have few moving parts, and the low risk inherent in operating them due to their size, an equivalent level of safety can be achieved by simply conducting test flights lasting at a minimum 15

minutes.

C. 14 C.F.R. 43. 11: Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§ 135.411(a)(1) and 135.419 of this chapter.

550 Productions , LLC requests an exemption from 14 C.F.R. 43.11. This part provides that maintenance records must be kept up to date by each inspector when an aircraft is deemed ready for return to service.

Equivalent level of safety: Because there are no certificated maintenance workers or inspectors for this type of aircraft as contemplated by this section, § 43.11 simply provides for no additional safety in flight. An equivalent level of safety will be achieved by testing the sUAS for 15 minutes of flight after each repair and/or modification by 550 Productions , LLC personnel. Also, the PIC will perform a

sho rt test flight prior to each operation in order to ensure proper functioning of the flight controls as described above.

D. 14 C.F.R. 45.11: Marking of products.550 Productions , LLC requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an approved fireproof identification plate.

The sUASs , due to their small size, do not have room for fireproof placards to be placed in or on th em. Any required placards could become hazardous, due to the additional weight and strain placed on the frame of the sUASs. Any additional weight could deteriorate the flight stability of the aircraft since they weigh less

than 10 lbs.

Equivalent level o f safety: 550 Productions , LLC’s flight crew will keep information related to the sUASs, including the user manual, at the ground station

and affix the N

- Numbers, once obtained from the FAA Registration Office, on the “arms” or fuselage of the sUASs as lar ge as practicably possible. The exemption will provide an equivalent level of safety to 14 C.F.R. 45.11 because the relevant documentation containing the serial number will be at the ground station with the PIC for inspection purposes rather than with the sUASs.

E. 14 C.F.R. 45.27: Location of marks; nonfixed

- wing aircraft.

550 Productions , LLC requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on bo th surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. The sUASs, due to their small size, do not have a cabin, fuselage, boom or tail in the ordinary sense, to display the marks required by §

45.23.

Equivalent level of safety: 550 Productions , LLC receives its N

- Number(s), it will display these marks on the “arms” or fuselage of the aircraft as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUASs will be regist ered with the FAA Aircraft Registration Branch. In the event of an incident, the sUASs will be traceable to 550 Productions , LLC.

F. 14 C.F.R. 45.29: Size of marks.

550 Productions , LLC requests an exemption from 14 C.F.R. 45.29. This part provides, in ter alia, at subsection (b)(3) that the registration marks for rotorcraft must be at least 12 inches high. The sUASs, due to their small size do not have any surface areas large enough to permit such markings of that size.Equivalent level of safety: Onc e 550 Productions , LLC receives its N

- Number(s), it will display these marks on the “arms” or fuselage of the aircraft al large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.29 because the sUASs will be regi stered with the FAA Aircraft Registration Branch. In the event of an incident, the sUASs will be traceable to 550

Productions , LLC.

G. 14 C.F.R. 61.113: Private pilot privileges and limitations: Pilot in command.

550 Productions , LLC requests an exempt ion from 14 C.F.R. 61.113. This part prohibits persons with private pilot certificates from operating an aircraft for hire. In Exemption No. 11062 to Astraeus Aerial, the FAA determined that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Therefore, 550

Productions , LLC requests a similar determination be made with respect to this petition.

Equivalent level of safety: The intent of requiring a commercial certificate before being able to operate an aircraft for hire is to protect human lives because most flights for hire are manned. Additionally, a commercial certificate equates to greater experience with aircraft. However, with respect to sUAS s, a commercial certificate does not result in greater flight experience. Instead, 550 Productions

, LLC will achieve an equivalent level of safety by ensuring all PICs go through a rigorous training program with Mr. Joshua Keffer involving a minimum of 3 h ours of simulator time and 10 flight hours in a multi

- rotor sUAS owned and operated by

550 Productions , LLC. Due to the inherent flight time restrictions caused by battery capacity, this equates to a minimum of 20 takeoff sequences and 20 landing

sequences

.

H. 14 C.F.R. 91.7(a): Civil aircraft airworthiness.

The FAA has previously stated that no exemption is required for a member of the DJI Phantom 2 family. 550 Productions , LLC reques ts a similar for its sUAS: the DJI Inspire 1. The Inspire 1 is signif icantly similar to the Phantom 2 in structure and operation, but with additional safety features, an improved flight control system, and improved electric motors.

In the alternative, and without abandoning the request above, 550 Productions

, LLC requests an exemption from 14 C.F.R. 91.7(a) on the following grounds. The regulation requires that no person may operate a civil aircraft unless it is inairworthy condition. Since there will be no airworthiness certificate issued for the

aircraft at issue in thi s petition, it would be impossible to comply with this regulation.

Equivalent level of safety: 550 Productions , LLC flight crews will achieve an equivalent level of safety by testing the sUAS for 15 minutes of flight after each repair and/or modification . Also, the PIC will perform a short test flight prior to each operation in order to ensure proper functioning of the flight controls as described above.

I. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard requirements.

The FAA has previously stated that no exemption is required for this se ction. See Exemption No. 11136. 550 Productions , LLC requests the same determination be made for this petition.

Alternatively, and without abandoning the argument above, 550 Productions , LLC requests exemption from 14 C.F.R. 91.9(b)(2) because it is impossible to comply with the regulation given the small size of the sUASs. The regulation requires “a current approved Airplane or Rotorcraft Flight Manual, approved manual materi al, markings, and placards, or any combination thereof” to be available in the aircraft. There is no room in the sUASs to store any extra materials, let alone a flight manual or placards.

Equivalent level of safety: 550 Productions , LLC and its agents wi ll achieve an equivalent level of safety by retaining all available manufacturer documentation in the travel case for each respective sUAS. This shall include the User Manual, Quick Start Guide, and other relevant safety information such as the “Battery

Sa fety Guidelines.” The flight crew will have these materials available to them because the case for the sUAS will remain at the ground station during flights.

J. 14 C.F.R. 91.9(c): Civil aircraft flight manual marking, and placard requirements.

550 Prod uctions , LLC requests an exemption from 14 C.F.R. 91.9(c). This part provides: “No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.”As stated above, 550 Productions , LLC w ill obtain an N

- Number from the FAA Registration Office and the sUASs, due to their small size, do not have room to contain placards, flight manuals, or 12

- inch markings required in part 45 of 14

C.F.R.

Equivalent level of safety: Once N 550 Productions

, LLC receives its N

- Number(s), it will display these marks on the “arms” or fuselage of the aircraft as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 91.9(c) because the sUASs will be registered with the F AA Aircraft Registration Branch. In the event of an incident, the sUASs will be traceable to 550

Productions , LLC.

K. 14 C.F.R. 91.103(b)(2): Preflight action.

The FAA has previously determined that relief fro m this section is not necessary

. 550 Produ ctions , LLC requests that a similar determination be made with respect to this petition.

Equivalent level of safety: Just as in Exemption No. 11138, 550 Productions , LLC requires certain preflight actions to be taken prior to each flight as outlined abov e in section III.C. of this petition. These actions include reviewing aeronautical chart data for the area of operations, reviewing applicable weather data, conducting a

pre

- flight inspection, calibrating the compass, acquiring GPS satellite signals and

pe rforming a very limited test flight. These preflight actions will ensure an equivalent level of safety with the requirements of § 91.103(b)(2).

L. 14 C.F.R. 91.105: Flight crewmembers at stations.

550 Productions , LLC requests an exemption from 14 C.F. R. 91.105 since this section is not applicable due to the sUASs carrying no flight crewmembers.

Equivalent level of safety: 550 Productions , LLC will not operate the aircraft

unless someone is at the controls at all times. The remote controller will be m anned regardless of whether the sUAS is engaged in a cinematic video shoot or conducting a pre

- programmed, automated aerial survey. Furthermore, as described above in section III. C. of this petition, the VO will always remain at the ground

station in voic e contact with the PIC. This will result in an equivalent level of safety as the requirements of § 91.105.M

. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests.

550 Productions , LLC requests an exemption from 14 C.F.R. 91.109. This regulation requires dual controls for aircraft when conducting flight instruction. The sUASs operated by 550 Productions , LLC do not have dual controls, or the capability to add a second remote controller, making compliance with this se ction impossible.

Equivalent level of safety: 550 Productions , LLC will be able achieve an equivalent level of safety during training flights because just like the throwover controls contemplated in this regulation, the remote controller can be easily

tr ansferred to the possession of the instructor midflight. This ability, combined with the low weight and unmanned nature of the aircraft certainly exceeds the level of safety provided by dual controls in a traditional manned aircraft during a training fligh t.

N. 14 C.F.R. 91.119: Minimum safe altitudes: General.

550 Productions , LLC requests an exemption from 14 C.F.R. 91.119. This regulation provides:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following a ltitudes:

(a) Anywhere . An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populate d areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

550 Productions , LLC intends to operate its sUASs at altitudes no greater than 400

feet AGL.

Equivalent level of safety: 550 Pr oductions , LLC’s operations will achieve an equivalent level of safety with this regulation by maintaining altitudes no greater than 400 feet AGL. This is in conformity with the operating standards set forth inAdvisory Circular (AC) 91

- 57. Additionally, t he sUASs flown and operated by 550

Productions , LLC all have GPS

- aided flight stability integrated into the flight control system. This allows the sUASs to maintain their position precisely when there are no inputs given through the remote controller. This allows the operator to make controlled, steady approaches to various obstacles for purposes of inspection, such as when taking images of cooling towers and smokestacks for regulatory compliance purposes. While flying close to such large obstructions poses a risk to the aircraft, the risk to infrastructure is negligible due to the weight of the sUASs being less than 10 lbs. The PIC shall always assess the risks to people and property when conducting such operations, and either continue the mission or abort accordingly.

O. 14 C.F.R. 91.121: Altimeter settings.

550 Productions , LLC requests an exemption from 14 C.F.R. 91.121. This regulation provides guidelines for altimeter use in maintaining the cruising altitude or flight level of the aircraft. Specific ally, the regulation calls for setting the altimeter of an aircraft referenced to mean sea level (MSL). Due to the limitations of the software provided by the manufacturer, it is impossible to comply with this requirement.

Equivalent level of safety: The sUASs operated by 550 Productions , LLC have flight control software which provides an altitude readout to the video screen attached to the remote controller. This altitude readout is always expressed as a

value in terms of feet or meters AGL. This value i s computed using GPS signals as well as an onboard barometer. Due to limitations in the software, it is impossible to cause the altitude readout to be expressed in terms of feet or meters above MSL.

550 Productions , LLC will achieve an equivalent level of safety by ensuring the maximum altitude is set to 400 feet AGL prior to each flight. The purpose of the regulation is to provide separation between aircraft during flight. Maintaining flight in class G airspace within VLOS during VMC at altitudes no greate r than 400 feet AGL (along with other operating procedures outlined above) will ensure that the sUASs do not interfere with the flight of other aircraft.

P. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions.

550 Productions , LLC requests an exemption from 14 C.F.R. 91.151. This regulation requires aircraft to have an amount of fuel that would carry the aircraft either 20 or 30 minutes beyond the intended landing point, dependent upon what type of aircraft is in use. It is impossible to co mply with this regulation due to thecurrent limitations of the sUASs in this petition; primarily because the sUASs carry no fuel at all, but only chemically stored energy in onboard batteries.

Equivalent level of safety: 550 Productions , LLC will achiev e an equivalent level of safety by requiring its PICs to initiate landing when the indicated battery level reaches 25% of its total capacity. This precaution, combined with the automated

return

- to

- home features built into the flight control system will pre vent the type of incidents in view with respect to § 91.151.

Q. 14 C.F.R. 91.203(a) & (b): Civil aircraft: Certifications required.

The FAA has previously determined that exemption from 14 C.F.R. 91.203(a) & (b) is not necessary. 550 Productions , LLC r equests a similar determination with respect to this petition.

Alternatively, and without abandoning the argument above, 550 Productions , LLC requests an exemption from 14 C.F.R. 91.203(a) & (b). This regulation requires, inter alia, that all aircraft ha ve current airworthiness certificates. This regulation cannot be complied with due to there being no certification process in place for aircraft of this type.

Equivalent level of safety: See section VI. H. of this petition, supra, at 13. An equivalent le vel of safety can be reached by ensuring that the flight crew perform

its duties in accordance with the manufacturers instructions and recommendations and in accordance with the procedures outlined in this petition above in section III. C., including, but not limited to, routine visual inspections of the equipment, regular firmware and software updates, as well as regular test flights under

controlled conditions.

R. 14 C.F.R. 91.215: ATC transponder and altitude reporting equipment and use.

550 Producti ons , LLC requests an exemption from 14 C.F.R. 91.215. It is impossible to comply with the requirement of this section when operating the sUASs covered by this petition. The sUASs are not equipped with radio equipment in order to transmit electromagnetic si gnals produced by a transponder. Furthermore, no sUAS operated by 550 Productions , LLC would be able to carry the additional weight of a transponder. For example, the Garmin GTX

- 327 digital transponder weighs 2.4 lbs.

- 37% of the weight of the Inspire 1.Equivalent level of safety: 550 Productions , LLC will achieve an equivalent level of safety by restricting all flights it conducts to altitudes no greater than 400 feet AGL within class G airspace only. Additionally, no flights will be conducted

within 5 nautical miles of an airport reference point as denoted on a current FAA

published aeronautical chart. These measures will reduce the risk of collision with another aircraft to a negligible level and likely exceed the level of safety achieved by a transpo nder.

S. 14 C.F.R. 91.403: General.

550 Productions , LLC requests an exemption from 14 C.F.R. 91.403. This regulation provides, inter alia, that the owner of an aircraft must maintain it in an airworthy manner and any maintenance performed on an aircra ft must be done in a

manner consistent with Part 43 of Title 14 of the C.F.R. 550 Productions , LLC will certainly maintain the airworthiness of its fleet of sUASs, but as discussed above in sections VI. B. & C. of this petition, there exists good cause to exempt 550

Productions , LLC from certain portions of Part 43 of Title 14 C.F.R.

Equivalent level of safety: An equivalent level of safety will be achieved by testing the sUAS for 15 minutes of flight after each repair and/or modification by 550

Productio ns , LLC personnel. Also, the PIC will perform a short test flight prior to each operation in order to ensure proper functioning of the flight controls as described above.

T. 14 C.F.R. 91.405: Maintenance required.

550 Productions , LLC requests an exempt ion from 14 C.F.R. 91.405. This regulation requires maintenance personnel to make repairs in accordance with Part 43 of Title 14 C.F.R. and to make entries in the maintenance records accordingly.

550 Productions , LLC contends that maintenance records for s UASs do not provide an additional amount of safety over regular inspections and test flights under controlled conditions. The sUASs operated by 550 Productions , LLC are so new that there exist no industry standard guidelines for when parts should be replaced following a given number of hours of operation. Documenting the length of time a certain part has been in operation will not give maintenance personnel

any meaningful data with respect to the expected lifetime or serviceability of that

part.

The quadricopters operated by 550 Productions , LLC only have four moving parts that affect their flight

- the four electric motors which power the propellers. Theattit ude, altitude, and velocity of the aircraft all vary by individually increasing or decreasing the speed of these four electric motors. The flight control system interprets inputs from the controller and through a complex array of algorithms

determines the necessary power inputs to the four electric motors in order to execute the desired maneuver. This system of flight control is far different from a standard aircraft which combines electronic and hydraulic systems with an internal combustion engine. While a standard aircraft has many points of failure, the nature of an sUAS is that malfunctions are immediately obvious upon takeoff: either the flight control system is operating correctly or not, either the electric motors are working or they are not, and so o n. Furthermore, due to the flight control system being driven by software, and the proprietary nature of the algorithms, there is no possible way to detect a potential failure in this system by visual inspections. Instead, the sUASs go through a type of “b oot up” process during which the

software runs certain self

- diagnostic tests. Given the low risk to life and property presented by sUASs weighing less than 10 lbs., keeping detailed maintenance records will simply not increase the level of safety beyond th at achieved by conducting regular test flights under strictly controlled conditions combined with visual inspections and the onboard self

- diagnostic software.

Equivalent level of safety: 550 Productions , LLC will achieve an equivalent level of safety, ta king into account the low weight of the sUASs, by conducting regular test flights and visually inspecting the physical elements of the flight control system as described previously in this petition.

U. 14 C.F.R. 91.407: Operation after maintenance, preve ntive maintenance, rebuilding, or alteration.

550 Productions , LLC requests an exemption to 14 C.F.R. 91.407. This regulation provides, in part, that no one may operate an aircraft after maintenance has been conducted upon it, unless the maintenance was in conformity with Part 43 of Title

14 C.F.R. 550 Productions , LLC has requested exemption from the applicable portions of Part 43 and therefore requests an exemption to this section as well.

Equivalent level of safety: 550 Productions , LLC personnel wil l inspect the physical parts of the sUAS for damage, wear, and other defects prior to each flight. This, combined with the self

- diagnostic features built into the sUASs and routine test flights after each repair and prior to each operation will allow for a n equivalent level of safety.

V. 14 C.F.R. 91.409: Inspections.550 Productions , LLC requests an exemption from 14 C.F.R. 91.409. This section provides specific requirements for inspections of aircraft, including annual inspections for airworthiness ce rtification. As discussed previously, regulations regarding airworthiness certification are largely inapplicable to sUASs due to there being no approved certification process in exist ence for this type of aircraft.

Equivalent level of safety: 550 Producti ons , LLC proposes in this petition to conduct visual inspections and test flights prior to each operation and following every repair or modification made to a sUAS. Thus, inspections of the sUASs will take place far more often than the 100

- hour interval an d/or annual inspections required by § 91.409.

W. 14 C.F.R. 91.417: Maintenance records

550 Productions , LLC requests exemption from 14 C.F.R. 91.417. This section is only applicable for aircraft with an airworthiness certificate. The sUASs will not have airworthiness certificates, therefore this section is inapplicable to sUAS operations.

Equivalent level of safety: 550 Productions , LLC does not intend to keep maintenance records for its sUASs due to the rapidly evolving nature of the industry which causes many sUASs to become obsolete in a matter of months, and the reasons set forth above in section VI. T. of this petit ion.