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 fo r 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 o peration 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 a nd 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 1 4 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 GPS

powered “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 condi tions. 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 chec klist 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 f light 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 operati on 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 individu ally 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 (w hen 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 Freque ncy: 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 w hen 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 oper ated 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 u se 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 ensu res 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 v isually 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 oper ated 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 sUA S;

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 les s 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.

 Writte n 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 pa yload (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 Perim eter 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 heavi ly 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 opport unities 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