June	11,	2015

U.S.	Department	of	Transportation

Federal	Aviation	Administration

800	Independence	Avenue,	SW

Washington,	DC	20591

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and Part	11	of	the	Federal	Aviation	Regulations	from:	14	CFR	61.113{a)	&	(b); 91.7	(a);	91.103;	91.119{c);	91.121;	91.151{a);	91.405{a);	91.407(a)(1); 91.409	(a)(1)	and	{2};	91.417{a)	&	(b ).

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act,	I,	Andrew Lassiter,	operator	of	an	Unmanned	Aircraft	System	(UAS),	hereby	apply,	on behalf	of	Keen	Eye	Marketing	and	Sea	Island	Media,	for	an	exemption	from
the	liste d	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial operation	of	its	UAS,	so	long	as	such	operations	are	conducted	within	and under	the	conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as required	by	Section	333.

I	would	like	to	form ally	submit	for	an	exemption	from	part	21,	subpart	H;	and Sections	45.23(b),	91.7(a),	91.9(b)(2),	91.119,	91.121,	91.151(a),	91.203(a) and	(b),	91.405(a),	91.407(a)(1),	91.409(a)(2),	and	91.417(a)	and	(b)	of	Title 14,	Code	of	Federal	Regulations	(14	CFR). This	proposed	exemption	would allow	the	operation	of	unmanned	aircraft	systems	(UAS)	for	the	purpose	of aerial	videography	and	photography	real	estate	purposes	and	events.Applicant:

Timothy	Jones

Owner

Timothy	Jones	Photography	LLC

24861	Planter s	Drive

Daphne,	Alabama	36526

Timljones@me.com

(251)	272

- 9198

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped with	camera	and	sensors,	would	operate	in	the	following	manner:!!! • Aerial	photography	and/or	video	for	public	and/or	p rivate	use	including real	estate	and	other	related	professional	activities.

• Aerial	video	and/or	photography	for	public	and/or	private	use	including public	and	private	events.

As	described	fully	below,	the	requested	exemption	would	permit	the

ope ration	of	a	UAS	under	controlled	conditions	in	the	NAS	that	would	be	a) limited,	b)	controlled,	c)	predetermined,	and	d)	will	provide	safety enhancements	to	the	already	safe	operations	in	the	industry	presently	using conventional	aircraft.	Approval	of	this exemption	would	thereby	enhance safety	and	fulfill	the	Secretary	of	Transportation	responsibilities	to “....establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in the	national	airspace	system.”

As	found	in	Exemption	No.	11138 (Trudeau),	the	FAA	recently	approved similar	use	of	a	PHANTOM	2	UAS.	We	will	operate	a	UAS,	the	DJI	Phantom	3 Professional,	Model	W323,	which	is	comprised	of	an	unmanned	aircraft	(UA or	Phantom),	an	attached	4K	camera	and	a	transportable	ground	station.	Th e PHANTOM	3	is	a	quad

- copter	with	a	gross	weight	of	2.8	pounds.	It	is equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	by batteries.	The	UA	has	a	maximum	airspeed	of	16	m/s.	It	will	be	operated	over various	metropolitan	areas,	primarily around	Charleston,	SC,	to	augment	real estate	listing	videos,	capture	event	areal	video	and	photography,	and	related business	operations.UAS	Operating	Parameters

We	will	abide	by	the	following	additional	operating	conditions	under	this exemption,	whic h	ensures	a	level	of	safety	at	least	equal	to	existing	rules:

• operate	UAS	below	300	feet	and	within	a	radius	distance	of	1000	feet	from the	controller	to	aid	in	direct	line	of	sight	visual	observation;

• obtain	permission	from	the	owner/controller	of	any vessels,	vehicles	and structures	when	operations	may	be	conducted	closer	than	500	feet	to any	such	vessels,	vehicles	or	structures;	we	will	conduct	a	safety assessment	of	the	risk	of	operating	closer	to	those	objects	and determine	that	it	does	not	present an	undue	hazard;

• operate	the	UAS	for	5

- 10	minutes	per	flight;

• land	UAS	prior	to	the	manufacturer’s	recommended	minimum	level	of battery	power;

• operate	UAS	during	daylight	hours	only	within	visual	line	of	sight	(VLOS);

• use the	UAS’	global	positioning	system	(GPS)	flight	safety	feature	whereby
it	hovers	and	then slowly	lands	if	communication	with	the	remote control	pilot	is	lost;

• conduct	all	operations	under	the	flight	safety	protocols	(including	posting	a warning	sign r eading:	“Attention	Aerial	Photography	in	Progress

– Remain	Back	150	feet”)	contained	in	the	operating	documents	and	will actively	analyze	flight	data	and	other	sources	of	information	to constantly	update	and	enhance	safety	protocols;

• contact	respective	a irports	if	operations	will	be	within	5	miles	to	advise them	of	his	estimated	flight	time,	flight	duration,	elevation	of	flight	and other	pertinent	information;

• always	obtain	all	necessary	permissions	prior	to	operation;	have procedures	in	place	to	abort flights	in	the	event	of	safety	breaches	or potential	danger;

• only	operate	in	safe	environments	that	are	strictly	controlled,	are	away from	power	lines,	elevated	lights,	airports	and	densely	populated	areas(defined	by	areas	depicted	in	“yellow”	on	VFR	ch arts	and	through obtaining	information	regarding	congested	areas	from	the	local	Flight Standards	District	Office	(FSDO);

• conduct	extensive	preflight	inspections	and	protocols,	during	which	safety carries	primary	importance	(reference	PHANTOM	Flying	Flow Chart and	User	Manual). Regarding	UAS	operational	training,	we	have	flown numerous	practice	flights	in	remote	areas	as	hobbyists	simulating flights	for	future	commercial	use	to	gain	familiarization	with	the characteristics	of	the	UAS’	performance	under	di fferent	temperature

and	weather	conditions.

Any	PIC	operating	our	UAS	will	have	accumulated	and	logged,	in	a	manner consistent	with	14	CFR	61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft pilot	including	at	least	10	hours	logged	as	a	UAS	pilot	with	a multi

- rotor	UAS. The	PIC	will	also	have	accumulated	and	logged	a	minimum	of	5	hours	as	a UAS	pilot	operating	the	same	make	and	model	of	UAS	to	be	used	for operations.	In	addition	to	the	hour	requirements,	the	PIC	will	accomplish	3
take

- offs	and	landings	i n	the	preceding	90	days	(for	currency	purposes)	prior to	any	flight.

Specific	Exemptions	Requested

Given	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the UA,	we	feel	an	exemption	from	14	CFR	part	21,	Subpart	H	(Airworthiness
Certif icates)	and	§	91.203(a)	and	(b)	(Certifications	required),	subject	to certain	conditions	and	limitations,	is	warranted	and	meets	the	requirements for	an	equivalent	level	of	safety	under	14	CFR	part	11	and	Section	333	of	P.L.

112

- 95	(Section	333).

We	reque st	an	exemption	from	§	45.23	Marking	of	the	aircraft	because	the	UA will	not	have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	words or	phrases.	Further,	the	two

- inch	lettering	is	difficult	to	place	on	such	a	small
aircraft	with	dimensions	sm aller	than	the	minimal	lettering	requirement. Regardless	of	this,	we	can	mark	the	UAS	in	the	largest	possible	lettering	by placing	the	word	“Experimental”	on	its	fuselage	as	required	by	§	45.29(f)	so that	anyone	will	see	the	markings.

We	request	an	exempt ion	from	§	91.7(a)	which	prohibits	the	operation	of	an aircraft	without	an	airworthiness	certificate,	since	there	is	currently	no certificate	applicable	to	our	operation,	this	regulation	is	inapplicable.

We	request	an	exemption	from	§§	91.405(a),	91.407(a )(1),	91.409(a)(2)	and91.417(a)	and	(b)	Maintenance	inspections	since	they	only	apply	to	aircraft with	an	airworthiness	certificate.	However,	as	a	safety	precaution	we	will perform	a	preflight	inspection	of	the	UAS	before	each	flight	as	outlined	in	the

at tached	operating	documents.

We	request	an	exemption	from	§	91.9(b)(2)	which	requires	an	aircraft	flight manual	in	the	aircraft,	however	since	there	are	no	pilots	or	passengers	on board	the	aircraft	and	given	its	size,	this	regulation	is	inapplicable.	We	b elieve an	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	safety/flight manual	with	the	UAS	ground	station.

We	request	an	exemption	from	§	91.119	which	prescribes	safe	altitudes	for the	operation	of	civil	aircraft,	but	it	allows	helicopters	t o	be	operated	at	lower altitudes	in	certain	conditions.	We	will	not	operate	our	UAS	above	the	altitude of	300	feet	above	ground	level	(AGL)	and	will	also	only	operate	in	safe	areas away	from	the	public	and	traffic,	thus	“providing	a	level	of	safety	at	leas t equivalent	to	or	below	those	in	relation	to	minimum	safe	altitudes.”	Given	the size,	weight,	maneuverability,	and	speed	of	the	UAS,	an	equivalent	or	higher level	of	safety	will	be	achieved.

We	request	an	exemption	from	§	91.121	Altimeter	settings	as	it is inapplicable	since	the	UAS	utilizes	electronic	GPS	with	a	barometric	sensor.

We	request	an	exemption	from	§	91.151(a)	Fuel	requirements	for	flight	in VFR	conditions.	The	UAV	is	100%	electric	and	two	low	battery	alerts	are
issued

- per	the	operating	doc uments,	the	UAV	will	be	landed	at	the	first	alert. Also,	our	flights	will	last	only	5

- 10	minutes	each,	and	the	UAS	has	an automated	function,	which	results	in	immediate	landing	when	a	low	battery	is detected.	The	PIC	will	not	begin	a	flight	unless	(conside ring	wind	and	forecast weather	conditions)	there	is	enough	power	to	fly	to	the	first	point	of	intended landing	and,	assuming	normal	cruising	speed,	land	the	UA	with	30%	battery power	remaining.

Public	Interest

Aerial	photography	and	videography	for	real	estate	and	events	are	proven strategies	to	enhance	marketing	efforts	and	increase	business	success.	The industry	is	not	new.	However,	until	recently	it	was	conducted	through	the	use of	costly	manned	aircraft,	a	p rohibitive	business	activity	for	small	companies. By	granting	this	exemption	I	would	be	able	to	provide	affordable	services.

Further,	the	small	UAS	will	pose	no	threat	to	the	public	given	its	small	size and	lack	of	combustible	fuel	when	compared	to	larger manned	aircraft. Additionally,	the	operation	of	our	UAS	will	minimize	harm	to	the	environmenteconomic	growth	by	providing	information	to	companies	and	the	public looking	to	relocate	or	build	in	the	metro	areas	we	service.	Public	and	private

events	servic ed	by	our	business	enhance	vibrancy	and	add	culture	to	the community	and	its	citizens.

Summary

We	will	comply	with	all	of	the	following	conditions	and	limitations	should	this exemption	be	provided:	1)	Operations	will	be	limited	to	the	following	aircraft described	in	the	operating	documents,	which	is	a	quad

- rotor	aircraft weighing	2.8	pounds:	Phantom	3	Unmanned	Aircraft	System.	2)	The	UA	will not	be	flown	at	an	indicated	airspeed	exceeding	50	knots.	3)	The	UA	will	be operated	at	an	altitude	of	no	more	than 400	feet	above	ground	level	(AGL),	All altitudes	reported	to	ATC	must	be	in	feet	AGL.	4)	The	UA	will	be	operated within	visual	line	of	sight	(VLOS)	of	the	Pilot	In	Command	(PIC)	at	all	times.	5) All	operations	will	utilize	a	visual	observer	(VO).	The	UA	w ill	be	operated within	the	visual	line	of	sight	(VLOS)	of	the	VO	at	all	times.	The	VO	and	PIC will	be	able	to	communicate	verbally	at	all	times.	The	PIC	will	be	designated before	the	flight	and	will	not	transfer	his	or	her	designation	for	the	duration
of	t he	flight.	The	PIC	will	ensure	that	the	VO	can	perform	the	functions prescribed	in	the	operating	documents.	6)	The	operating	documents	will	be accessible	during	UAS	operations	and	made	available	to	the	Administrator upon	request.	Any	revisions	to	the	opera ting	documents	will	be	presented	to the	Administrator	upon	request.	7)	Prior	to	each	flight,	the	PIC	will	inspect the	UAS	to	ensure	it	is	in	a	condition	for	safe	flight.	If	the	inspection	reveals	a condition	that	affects	the	safe	operation	of	the	UAS,	the UAS	will	not	be operated	until	the	necessary	maintenance	has	been	performed	and	the	UAS	is found	to	be	in	a	condition	for	safe	flight.	The	Ground	Control	Station	will	be included	in	the	preflight	inspection.	All	maintenance	and	alterations	will	be properly documented	in	the	aircraft	records.	8)	Any	UAS	maintenance	or alterations	that	affect	the	UAS	operation	or	flight	characteristics,	e.g. replacement	of	a	flight	critical	component,	will	undergo	a	functional	test flight.	The	PIC	who	conducts	the	functional test	flight	will	make	an	entry	in the	aircraft	records.	9)	The	pre

- flight	inspection	section	in	the	operating documents	will	account	for	all	discrepancies,	i.e.	inoperable	components, items,	or	equipment,	not	already	covered	in	the	relevant	sections	of	the operating	documents.	10)	We	will	follow	the	UAS	manufacturer’s aircraft/component,	maintenance,	overhaul,	replacement,	inspection,	and	life limit	requirements.

11)	We	will	carry	out	maintenance,	inspections,	and	record	keeping requirements,	in	accordance with	the	operating	documents.	Maintenance, inspection,	and	alterations	will	be	noted	in	the	aircraft	records,	including	totalflight	hours,	description	of	work	accomplished,	and	the	signature	of	the authorized	person	returning	the	UAS	to	service.	12)	Each UAS	operated	will comply	with	all	manufacturer	Safety	Bulletins.	13)	An	authorized	person	will make	an	entry	in	the	aircraft	record	of	the	corrective	action	taken	against discrepancies	discovered	between	inspections.	14)	UAS	operations	will	be
conducted	b y	a	PIC	possessing	at	least	a	private	pilot	certificate	and	at	least	a
current	third

- class	medical	certificate.	The	PIC	will	also	meet	the	flight	review requirements	specified	in	14	CFR	61.56	in	an	aircraft	in	which	the	PIC	is	rated on	his	or	her	pilot	cer tificate.	15)	Prior	to	operations	conducted	for	the purpose	of	aerial	videography/photography	and	for	real	estate	listing	videos and	public	and	private	events	and	similar	operations,	the	PIC	will	have accumulated	and	logged,	in	a	manner	consistent	with	14 CFR	61.51(b),	a minimum	of	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	including	at	least 10	hours	logged	as	a	UAS	pilot	with	a	multi

- rotor	UAS.	16)	Prior	to	operations conducted	for	the	purpose	of	aerial	videography/photography	and	for	real
estate	li sting	videos	and	public	and	private	events	and	similar	operations,	the PIC	will	have	accumulated	and	logged,	in	a	manner	consistent	with	14	CFR 61.51(b),	a	minimum	of	5	hours	as	UAS	pilot	operating	the	make	and	model	of the	UAS	to	be	used	in	operations.	Th e	PIC	will	accomplish	3	take

- offs	and landings	in	the	preceding	90	days.	17)	The	PIC	will	not	operate	the	UAS	for the	purpose	of	aerial	videography/photography	and	for	real	estate	listing videos	and	public	and	private	events	and	similar	operations,	unless the	PIC has	demonstrated	and	logged	in	a	manner	consistent	with	14	CFR	61.51(b), the	ability	to	safely	operate	the	UAS	in	a	manner	consistent	with	the operating	documents,	including	evasive	and	emergency	maneuvers	and maintaining	appropriate	distances	from people,	vessels,	vehicles	and structures.	18)	UAS	operations	will	not	be	conducted	during	night,	as	defined in	14	CFR	1.1.	All	operations	will	be	conducted	under	visual	meteorological conditions	(VMC).	19)	The	UA	will	not	operate	within	5	nautical	miles	o f	an airport	reference	point	as	denoted	on	a	current	FAA

- published	aeronautical chart.	20)	The	UA	will	not	be	operated	less	than	500	feet	below	or	less	than 2,000	feet	horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute
miles	from	the	PIC. 21)	If	a	UA	loses	communications	or	loses	its	GPS	signal,	it will	return	to	a	predetermined	location	within	the	planned	operating	area and	land	or	be	recovered	in	accordance	with	the	operating	documents.	22) The	PIC	will	abort	a	flight	in	the	event	of	unpr edicted	obstacles	or emergencies	in	accordance	with	the	operating	documents.	23)	The	PIC	will not	begin	a	flight	unless	(considering	wind	and	forecast	weather	conditions) there	is	enough	power	to	fly	at	normal	cruising	speed	to	the	intended	landing point	a nd	land	the	UA	with	30%	battery	power	remaining.	24)	We	will	obtain an	Air	Traffic	Organization	(ATO)	issued	Certificate	of	Waiver	or Authorization	(COA)	prior	to	conducting	any	operations,	and	also	request	aNotice	to	Air

- man	(NOTAM)	not	more	than	72	hour s	in	advance,	but	not	less than	48	hours	prior	to	the	operation.	25)	Before	conducting	operations,	the radio	frequency	spectrum	used	for	operation	and	control	of	the	UA	will comply	with	the	Federal	Communications	Commission	(FCC)	or	other appropriate	gover nment	oversight	agency	requirements.	26)	The	documents required	under	14	CFR	91.9	and	91.203	will	be	available	to	the	PIC	at	the Ground	Control	Station	of	the	UAS	any	time	the	UAS	is	operating.	These
documents	will	be	made	available	to	the	Administrator	or any	law enforcement	official	upon	request.

27)	The	UA	will	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation operations	and	activities	at	all	times.	28)	The	UAS	will	not	be	operated	by	the PIC	from	any	moving	device	or	vehicle.	29)	The	UA	wi ll	not	be	operated	over congested	or	densely	populated	areas.

30)	Flight	operations	will	be	conducted	at	least	500	feet	from	all nonparticipating	persons,	vessels,	vehicles,	and	structures	unless:

a.	Barriers	or	structures	are	present	that	sufficiently	p rotect	nonparticipating persons	from	the	UA	and/or	debris	in	the	event	of	an	accident.	We	will	ensure that	nonparticipating	persons	remain	under	such	protection.	If	a	situation arises	where	nonparticipating	persons	leave	such	protection	and	are	within
500 feet	of	the	UA,	flight	operations	must	cease	immediately	and/or;

b.	The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the owner/controller	of	such	vessels,	vehicles	or	structures	has	granted permission	and	the	PIC	has	made	a	safety	asses sment	of	the	risk	of	operating closer	to	those	objects	and	determined	that	it	does	not	present	an	undue hazard,	and;

c.	Operations	nearer	to	the	PIC,	VO,	operator	trainees	or	essential	persons	do not	present	an	undue	hazard	to	those	persons	per	§	91.119(a ).	31)	All operations	will	be	conducted	over	private	or	controlled

- access	property	with permission	from	the	land	owner/controller	or	authorized	representative. Permission	from	land	owner/controller	or	authorized	representative	will	be
obtained	for	each	fli ght	to	be	conducted.	32)	Any	incident,	accident,	or	flight operation	that	transgresses	the	lateral	or	vertical	boundaries	of	the operational	area	as	defined	by	the	applicable	COA	will	be	reported	to	the FAA's	UAS	Integration	Office	(AFS

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

.
If	you	have	questions	or	need	additional	information,	please	contact	me	attimljones@me.com or	(251)	272

- 9198.

Thank	you,

Timothy	Jones

Owner:	Timothy	Jones	Photography	LLC