December 21, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Sir or Madam: 

I respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the 

Federal Aviation Regulation in order for my company, Mountain State Overland LLC, to utilize a 

small Unmanned Aircraft System (sUAS) for commercial purposes. Mountain State Overland 

LLC is a small brand marketing firm and we will be using a sUAS for photography and 

videography. We intend to incorporate the use of a sUAS for a variety of media projects that 

include aerial photography and aerial videography for marketing, advertising and promotional 

purposes.

PETITIONER 

Jason Kristopher Specht, Owner

Mountain State Overland LLC

P.O. Box 48

Montvale VA 24122 

Telephone: (540) 968-0069

Email: jason@mountainstateoverland.com

EXTENT OF RELIEF REQUESTED 

This is a request for relief to permit commercial operations of a sUAS for operations conducted 

within and under the conditions outlined herein or as may be established by the Federal Aviation 

Administration (FAA) as required by Section 333. 

This exemption would permit the operation of sUAS under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, 

Mountain State Overland LLC would conduct commercial operations of sUAS meeting or 

exceeding all operational and safety requirements per Section 333 and other pertinent 

information contained within this request. 

SPECFIC SECTIONS SEEKING EXEMPTION

 14 C.F.R Part 21 

 14 C.F.R. 45.23(b) 

 14 C.F.R. 61.113(a) 

 14 C.F.R. 91.7(a) 

 14 C.F.R. 91.9(b)(2 

 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. 91.203(a) and (b) 

 14 C.F.R. 91.215 

 14 C.F.R. 91.104 through 91.417 

EQUIPMENT 

Mountain State Overland LLC has acquired a DJI Phantom 3 Professional quad copter. The 

Phantom 3 Professional is equipped with a built-in GPS-enabled “geofence” that prevents the 

operator from flying into unwanted and protected airspaces. This sUAS also features vision 

positioning with sensors that monitor its position and enabling it to maneuver more accurately 

and responsively. Additional safety features include an auto-takeoff feature as well as a GPSpowered “Auto Return Home” feature that instructs the sUAS to fly back to its take-off location 

automatically in the case of low battery or loss of communication. The "Auto Return Home" 

feature can also be engaged with the touch of a button on the remote and can be canceled if 

obstructions prevent the sUAS from returning safely. 

For additional safety and control, the Phantom 3 Professional is equipped with a live-video feed 

that's transmitted to a tablet or phone connected to the remote control for real-time operator 

awareness and vision. Mobile devices also display flight details including location, speed, height, 

distance, battery power and general aircraft conditions. Mountain State Overland LLC will only 

permit an operator to operate the sUAS in intervals less than 15 minutes to ensure that battery 

power is reserved in the event the "Auto Return Home" feature fails. 

All flights will begin with a pre-flight checklist including a review of the working parts, propellers, 

motors, camera, remote, mobile devices and radios used by a Visual Observer. Flight logs are 

captured automatically and include route, flight time, distance and location. Operators must 

present a flight log or similar evidence that indicates no less than 20 hours of flight time 

operating a Phantom 3 Professional or similar sUAS. Operators will be required to complete an 

operation test that indicates they retain a skill set that warrants safe operation of said sUAS. 

Operation testing will take place at an altitude of no greater than 10 feet and the operator must 

fly the sUAS forward, backward, and laterally navigate with the use of device, a Visual Observer 

and while observing flight patterns individually without the use of a mobile device. 

Quad Copter Specifications: 

 Weight (Including Battery And Propellers): 1280 g 

 Diagonal Size (Including Propellers) 590 mm 

 Max Ascent Speed: 5 m/s 

 Max Descent Speed: 3 m/s 

 Hover Accuracy 

o Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

o Horizontal: +/- 1.5 m 
 Max Speed: 16 m/s (ATTI mode, no wind) 

 Max Altitude Above Sea Level: 6000 m 

 Operating Temperature: 0°C to 40°C 

 GPS Mode: GPS/GLONASS 

Remote Control Specifications: 

 Operating Frequency: 2.400 GHz-2.483 GHz

 Max Distance:

o Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant

o Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant

 Video Output Port: USB

 Operating Temperature: 0°C- 40°C

 Battery: 6000 mAh LiPo 2S

 Mobile Device Holder

 Receiver Sensitivity (1%Per): -101 dBm ±2 dBm 

 Transmitter Power (Eirp) • FCC: 20 dBm

 CE: 16 dBm

 Working Voltage: 1.2 A @7.4 V 

PUBLIC BENEFIT

Aerial photography and videography can cost thousands of dollars when the use of manned 

fixed-wing aircraft and helicopters is required. Unfortunately, this is cost-prohibitive for 

individuals and small businesses that seek services that require aerial photo and video for 

marketing purposes. By utilizing a sUAS, Mountain State Overland LLC will provide aerial photo 

and video services at a significantly lower cost thus making aerial photography and videography 

a cost effective option for our clients so they to can benefit from quality media.

Furthermore, a sUAS can be operated much more safely and with less risk to the public and 

surrounding natural environments than helicopters and fixed-wing aircraft. At Mountain State 

Overland LLC, its important that our media have little to no impact on our natural environment 

and the use of a sUAS provides us an opportunity to manage our standards for reducing carbon 

emissions.

The general goal of Mountain State Overland LLC is to operate a sUAS with safety and 

professionalism as its top priority. Other than training, flight operations will be limited to 

predetermined flight paths in conjunction with the creative visions associated with projects we 

work on. Operations will terminate during intervals where our sUAS is not setup to capture still 

or motion images. This simple objective ensures we are professionally representing our 

business and other companies that operate a sUAS for commercial purposes.

SAFETY 

Provided an exemption is granted, Mountain State Overland LLC will comply with all the 

following conditions and limitations listed below and any others that are assigned by the FAA: 
 Operations will be limited to the DJI Phantom 3 Professional; 

 Flights will be operated within the visual line of sight of the operator and a Visual 

Observer;

o When obstructions prevent the operator from visually tracking the sUAS, at least 

one (1) Visual Observer will position themselves so that that the sUAS can be 

tracked and its position can be reported back to the operator using radio 

communications;

 Flights will be operated during daylight hours only;

 Maximum flight time for each operational flight will be less than 15 minutes AND the 

operator will be instructed to return the sUAS to it's original takeoff location prior to 

consuming battery power reservations (20% battery power); 

 Flights will be operated at an altitude that never exceeds 400 feet AGL; 

 Minimum crew for each operation will consist of the sUAS operator and at least one (1) 

Visual Observer; 

 A briefing will be conducted by all personnel operating and observing prior to operating 

said sUAS;

o Brief will include at a minimum:

 Predetermined flight paths;

 Assessments of weather conditions, including wind speeds, and 

awareness of natural, live and structural objects that may present risk;

 Operations of the sUAS will be limited to wind speeds less than 

10mph at ground level where they can be effectively measured 

and monitored with the use of an handheld anemometer

 Procedures for emergency landing; and

 Radio communication checks.

 All onsite personnel and client employees will be required to execute verbal and/or 

written waiver permitting the flight of said sUAS within 100 feet of flight operation;

o No flight operations will be conducted within 500 feet from nonparticipating 

persons, vessels, vehicles, and structures.

 Written and/or verbal permission from relative property owners will be obtained prior to 

operating the sUAS; 

 All permits, permissions, etc. will be obtained from local government offices as required;

 The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); 

 The sUAS will operate at speeds less than 30 knots, hover and simultaneously move 

vertically and horizontally; 

 The sUAS will have the capability to return and land at the pre-determined location with 

the Security Perimeter should the sUAS lose communication or GPS signal during any 

operations; 

 The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies; 

 Flight operation will not be conducted over densely populated areas or heavily traffic 

highways;
 Flight operation will be restricted from flying within 5 nautical miles of airports unless a 

letter of agreement with respective airport management is obtained. The letter of 

agreement with airport management must be made available to any law enforcement 

official or administrator upon request.

On behalf of Mountain State Overland LLC, I want to thank you for your consideration in 

granting this exemption. It would be my sincere honor to hold this exemption and it would 

present new opportunities to ensure the success of my business and our clients. 

Thank you for your time and consideration, 

Jason Kristopher Specht, Owner

Mountain State Overland LLC

P.O. Box 48

Montvale VA 24122

Telephone: (540) 968-0069

Email: jason@mountainstateoverland.com