I. Name and Information

Scott Dodson 6810 High Country Trail Arlington, Texas 76016

214

- 683

- 1948
scott.dodson@tx.rr.com Owner, Vid Flight (a subsidiary of Live It Again Productions, LLC) All mentions of my name "Scott Dodson" are inclusive of "Vid Flight"

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Scott Dodson Requests Exemption are: 14 CFR 21;§14 C.F.R. 45.23(b);§14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.;§14 CFR 407 (a) (1);§14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent o f relief Scott Dodson seeks and the Reason He Seeks Such

Relief:

I, Scott Dodson, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Scott Dodson, c ontemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the pub lic’s interest to do so.

My, Scott Dodson's, ultra light weight UAS meets the definition of “small

unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I woul d like
to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that

can be administered uniformly to all UAS aerial video and photography.

The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall cap abilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Scott Dodson.

M y UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal.I, Scott Dodson, consider safety as foremost with each flight. My small, unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly

in winds exc eeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the GPS Mode for aerial videography/photography. This is the safest, most r eliable and stable mode to
prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the

nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot, or with my licensed PIC. Utilizing battery power rather than combustible fuels, flights generally last between three (3) to twelve (12) minutes, with an altitude under two hundred (200) feet. I, Scott Dodson, utilize a fresh fully charged battery wi th each flight as a safety precaution; full flight time limit for each battery is twelve (12) to twenty

two (22) minutes as tested. I do not operate my UAS at or below manufacture

recommend minimum charge levels for operation; preferring to remain well wit hin a safe operating range to insure adequate communication between radio control

and UAS to eliminate potential for crash, loss of control or hazard. Reserve

batteries are at hand with each exercise to insure replacement for sufficient safe level of opera tion. I do not believe in taking risk that may cause a crash, that

could create hazard to the public/property/manned aircraft, and have no desire to

lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating fligh ts for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature

and weather conditions. I also practice computerized simulated flights to maintain adequate skills and res ponse ref lex time, a ll for the sake of safety.

I, Scott Dodson, am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's

into the national airspace system. Scott Dodson’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.IV. How Scott Dodson’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibi tive. The same is also true for construction sites, land sur veying, and even loc ation historical documentation. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non

- luxury homeowners and lower budget Realtors and other such companies with needs from a valu able marketing and analysis tool. Manned aircraft pose a threat to the public through potential catastrophic crash in the North Texas community, e ach resu lting in loss of life,

and with combustible fuel that exploded and burned on impact. Police, TV and

ra dio helicopters have made emergency hard landings within city limits.

My, Scott Dodson’s, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the pub lic’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Scott Dodson’s, exemption request furthers the public interest through

academic/visual awareness of the geographical benefits in and around the North

Texas area. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing air craft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting me, Scott Dodson, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the North Texas community for companies looking to relocate or build in the North Texas area as well as individuals looking

to relocate for career advancement through academic and geographical

awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Scott Dodson’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Scott Dodson’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Scott Dodson, to log more flight

time in FAA controlled airspace, with communicat ion with the FAA, will allow me

to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors, cons truction sites, land surveying,

location historic al documentation, and infrastructure inspections that can beembraced by the NAR, AAR, and TAR for deve lopment in cooperation with the FAA. In addition I, Scott Dodson, submit the following representations of enhancements to current aerial videography and photography for real estate, construction sites, land surveying, location historical documentation, infrastructure inspections, athletic field marketing and maintenance:

My UAS, a Phantom 2 manufactured by DJI wei ghs less than 5 pounds complete

with a sma ll ultra light weight high quality GoPro 3+ Black camera;

§I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operates for 12

- 16 minutes per flight; §I land my UAS prior to manufacturer recommended minimum level of battery

power; §I pilot my UAS through remote control only by line of sight; §My UAS has GPS a flight safety feature whereby it hovers and then slowly lands

if communication with the remote control pilot is lost; §I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; §I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airp orts and actively populated areas; §I conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance; §I always obtains all necessary permissions prior to operation; and, §I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, Scott Dodson’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of

commercial UAS into our national airspace syst em, helicopters are the primary

means of aerial video and photography for community awareness and application. While the safety record of such helicopters is remarkably astounding,

there have been local incidents involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS. §First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas away from mass populations. §Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. §Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. §Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused

on through the technology and use of post editing software allowing pan and

zoom. Accordingly, my UAS has been experimenta lly operated for familiarization/competency and will continue to operate at and above current safety levels.VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Scott Dodson's, UAS permi ts exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333

of the Reform Act. The FAA is authorized to exempt aircraft from the

airworthiness certificate requirement under both the Act (49 U.S.C. § 44 701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of

the weight, size, speed, maneuverability and proximity to areas such as airports

and de nse populations. My, Scott Dodson, current and projected UAS's meet or

exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contem plated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10 167, 10167A,
10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Scott Dodson.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark ce rtain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possiblelettering by placing the word “EXPERIMENTA L” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

commercial operations. I, Scott Dodson, can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the

risk levels inherent in the comm ercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Scott Dodson, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescr ibes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Scott Dodson, wi ll however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or hig her level of safety will

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as pres cribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an

airw orthiness certificate. They will not, therefore, apply to my, Scott Dodson's, UAS. However, as a safety precaution I carefully and thoroughly inspect my UAS before and after each flight.

In summary, Scott Dodson seeks an exemption from the following Regul ations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.20 3(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R.§ 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Scott Dodson, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, grounds and building maintenance, infrastructure inspections, real estate operations, and to develop economic platforms for real

estate to enhance the experience of those seeking to relocate to the North Texas

area. Currentl y, such aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Scott Dodson, request for exemption will reduce current risk levels and thereby enhance saf ety.

My UAS craft do not contain potentially explosive fuel, is smaller, lighter and

more maneuverable than conventional video and photographic aircraft with much

less flight time. Further, I operate at lower altitudes and in controlled airspace

eliminati ng potential public risk flying to and from established air fields. I, Scott Dodson, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for aerial video and photographic u sage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA

Modernization and Reform Act of 2012. Th ere are no personnel on board my, Scott Dodson, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Scott Dodson's, operation of my UAS, weighing less than 5 pounds and traveling at lower speeds within limite d areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Scott Dodson, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully Submitted,

Scott Dodson, Owner Vid Flight Subsidiary of Live It Again Productions, LLC

6810 High Country Trail Arlington, Texas 76016