September 11. 2015 U.S. Department of Transportation Federal Aviation Administration Docket Management System West Building Ground Floor, Room W12-140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR part 21, subpart H; 14 C.F.R. 45.23(b);14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b).

Dear Sir or Madam: Pursuant to Section 333 of FAA Modernization Act of 2012 and 14 CFR Part 11, Beefree Media, LLC, a newly formed triple bottom line business solutions and marketing agency hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow structured and safe low altitude commercial operations of it’s Small Unmanned Aircraft Systems (“sUAS”) so long as such operations are conducted within and under the conditions and limitations outlined herein or as may be established by the FAA as required by Section 333.

Sincerely,

Jared Jacobs, Managing Partner, Beefree Media, LLC

Applicant Contact Information: Jared Jacobs Beefree Media, LLC 2312 N-Miami Ave Miami, FL. 33145 PH: 937-657-8031 Email: jared@beefreemedia.com

of 1 18Table of Contents Glossary of Abbreviations ................................................................................... 3

List of Exhibits ................................................................................................... 4 Statutory Authority for Exemption ........................................................................ 5

Section 1: Introduction ........................................................................................ 6 Section 2: Unmanned Aerial Systems .................................................................... 6 Section 3: Unmanned Aircraft Pilot in Command (PIC) ............................................ 8 Section 4: Operation of the Unmanned Aircraft ...................................................... 9 Requested Exemptions from Regulations ........................................................... ...13

Public Interest ............................................................................................... .....17 Summary for the Federal Register ......................................................................... 18

of 2 18Glossary of Abbreviation

AGL Above Ground Level ATC Air Traffic Control COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation FCC Federal Communications Commission MAAP Mid Atlantic Aviation Partnership NAS National Airspace System NTSB National Transportation Safety Board PIC Pilot in Command PQS Personnel Qualification System SOP Standard Operating Procedures sUAS Small Unmanned Aircraft Systems VFR Visual Flight Rules VMC Visual Meteorological Conditions VO Visual Observer VLOS Visual Line of Sight

of 3 18List of Exhibits:

1.) Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log 2.) Beefree Media Motion Picture and Television Flight Operation Manual

Please follow the link below to review the following DJI-Inspire 1 Manuals and Safety Guidelines. www.dji.com/product/inspire-1/spec

1.) Inspire 1 Quick Start Guide (EN) v1.0 2.) Inspire 1 User Manual (EN) v1.0 3.) Inspire 1 Safety Guidelines v 1.0 4.) Inspire 1 Intelligent Flight Battery Safety Guidelines 5.) 1345 Propeller Locks Quick Start Guide 6.)Inspire 1 Maintenance Manual v 1.0

Please reference to the following tutorial videos for DJI Inspire 1 below. www.dji.com/product/inspire-1/video

1.)DJI Inspire 1 – Unboxing and Preparing for Safe Flight 2.) DJI Inspire 1 Tutorial “Pilot App” 3.)DJI Inspire 1 Tutorial “Updating the Firmware” 4.)DJI Inspire 1 Tutorial “Dual Operator” 5.)DJI Inspire 1 Tutorial “How to Fly” 6.) DJI Inspire 1 Quick Start Guide 7.)DJI Inspire 1 Set Up & Demo Inc. Overview of Features of the App 8.)DJI Inspire 1 Flight Simulator for Apple App intro duction

of 4 18Statutory Authority for Exemption: Detailed in this document and the referenced DJI Publications and tutorials; the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is: A.) limited B.) predetermined C.) controlled to access D.) Provide safety enhancements to the already regulated safety practices presently followed by manned aircraft as governed by the FAA. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibility to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act

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The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702 – 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; CFR §91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace System without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider: a.) The sUAS’s size, weight, speed and operational capability b.) Whether the sUAS operates within the VLOS of the PIC c.) Whether the sUAS operates outside of highly populated areas and away from close proximity to airports Reform Act §333(a). If the Secretary determines that a sUAS “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

of 5 18Section 1: Introduction Beefree Media is recognized as a pillar of support for community and small business development in South Florida. The mission of Beefree Media is to provide unmatched quality in our service to business and community development. Our objective on every mission is to serve as an example in regards to safety and professionalism to the public.

Section 2: Unmanned Aerial Systems 1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners should describe the design and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft performance and performance limitations, operating procedures, and aircraft loading information in as much detail as possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document. NOTE: The FAA will consider all information and data submitted by the petitioner that describes the UAS developmental and operational history. This could include statistical data or other documentation for the specific design and performance characteristics of the UAS, including the operational history and operational failure modes, obtained through previous Research & Development (R&D) and/or flight test activities, e.g. operations conducted under a COA, with a civil airworthiness certificate, or under other authorized operating conditions. 2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate documents or combined in a single document. 3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC requirements upon request. Beefree Media will operate all sUAS under fifty-five pounds including payload within NAS aerospace with the experience of Beefree Media sUAS flight training. Beefree Media preflight procedures are designed to reduce risk and mitigate both mechanical and user error for maximum safety in the support of and in accordance with the FAA’s mission to provide the safest, most efficient aerospace system in the world. Prior to each flight the PIC will thoroughly reference and provide entry into the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log. If a situation arrises where the PIC finds operation procedure or the sUAS to be affected or incomplete, the PIC will reframe from operation until all necessary tasks, maintenance and alterations are performed insuring the proper conditions for a safe flight. All operations, maintenance and alterations will be documented by the PIC within the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Log.

of 6 18All maintenance or alteration procedures will be logged within the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log as well as test flights for functionality in accordance to the manufactures guide. The radio frequency spectrum used for remote control and operation with the sUAS will comply with the Federal Communication Commission (FCC) and all other appropriate government oversight agency requirements.

DJI Inspire 1 Beefree Media LLC. seeks an exemption to operate the DJI Inspire 1 sUAS for compensation or hire. The DJI Inspire 1 is comprised of a quad-rotor unmanned aircraft with four rotors powered by four lithium polymer battery powered electric motors including up to two handheld ground control stations. Flight weight: approximately 6.5 pounds Dimensions: 438mm x 451mm x 301mm

Design and operational characteristics are provided in DJI Inspire 1 Operating Manual (Pages 57-59). Beefree media PIC sUAS operators will conduct pre-flight inspections as documented in the Beefree Media sUAS Safety Standard Operation Procedure Checklist and Pilot Log as well as the DJI Inspire 1 Operating Manual (Page 49).

of 7 18Section 3: Unmanned Aircraft Pilot in Command (PIC) Regarding the Unmanned Aircraft PIC 4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including information such as: the level of airman certificate held; any applicable training related to the operation; and any minimum hours of flight experience required by the PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual observers, petitioners should describe their roles and qualifications. 5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for the operation of the UAS. All sUAS operators including both the PIC and VO will have both a valid state drivers license and an applicable knowledge of and compliance with Agency regulations relative to the location of sUAS operation. Included in the sUAS operators applicable knowledge and compliance are the articles of the Title 14 Code of Federal Regulations segments below. 61.51 Pilot logbooks 61.56 Flight review 91.111 Operating near other aircraft 91.113 Right-of-way rules: Except water operations 91.115 Right-of-way rules: Water operations 91.119 Minimum safe altitudes: General The PIC in operation of the sUAS for a Beefree Media service must have a minimum of 10 hours of logged flight time with the specific sUAS make and model consistent with 14 CFR Section 61.51(b) and 25 total hours of flight time. PIC and VO sUAS training and experience building flights are requested to occur under this grant of exemption. All sUAS flight training sessions will take place with the required distance from non-participants in accordance with the Title 14 Code of Federal Regulations. In accordance with all FAA approved exemptions, A VO will be present on all operations to maintain Visual Line of Sight (VLOS) at all times while maintaining the ability to verbally communicate. The PIC will either maintain VLOS at all times or maintain the ability to achieve VLOS when a VO is present on operations. A VO will always be present on all operations.

of 8 18Section 4: Operation of the Unmanned Aircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure public safety, which includes persons and property both in the air and on the ground. This can be described in the petition, in an Operations Manual, or similar document. NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, NAS safety considerations, and the safety of the non-participating persons and property during the operational period and within the operational area.

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an Operations Manual, or similar document. The sUAS will remain clear of and always yield the right of way to all other manned aerospace operations and activities. The multi-rotary sUAS operation will operate at altitudes no higher than 400 feet above ground level (AGL) nor flown in speeds exceeding design limitation of 43 knots or 50mph. All altitudes will be reported to the ATC in feet. The PIC will always operate the sUAS with optimal battery power to return the sUAS to the predetermined (home) location with no less than 25% power remaining. The PIC will at all times operate the sUAS under Visual Meteorological Conditions (VMC) and will never operate the sUAS when visual conditions are less than 3 miles or 1500 feet. Operations will never occur at at night. The PIC will not operate the sUAS less than 500 feet below or less than 2,000 feet horizontally from a cloud. The PIC operating the sUAS will abort the flight in the event of unpredicted obstacles or emergencies. Upon the loss of GPS signal the PIC will return the sUAS to the predetermined (home) location or perform emergency landing and/or recovery measures as outlined in the Beefree Media Safety Standard Operating Procedures Checklist and Pilot Log. A serial number will identify the sUAS proposed for exemption registered in accordance with 14 CFR part 47.

45.1 to 45.33 - IDENTIFICATION AND REGISTRATION MARKING 47.1 to 47.71 - AIRCRAFT REGISTRATION At all times the PIC will have access to appropriate documents in accordance with 14 CFR 91.203 and 14 CFR 91.9. Upon request, law enforcement will have access and availability to these documents. Upon the occasion of a sUAS failing to maintain boundaries of operation as defined applicable, a report will be filed to the FAA UAS Integration Office (AFS-80) within 24 hours. All incidents and accidents will be reported to the National Transportation Safety Board (NTSB).

91.203 Civil aircraft: Certifications required 91.9 Civil aircraft flight manual, marking, and placard requirements

of 9 188. Petitioners should describe the characteristics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory mandate under Section 333 regarding proximity to populated areas. These issues can be addressed in the petition, an Operations Manual, or similar document. Operations of sUAS may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary; but never so close to present an undue hazard. Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission, and the PIC makes a safety assessment of the risk from operations and determines that it does not present an undue hazard to persons or property. Flight operations will be conducted at least 500 feet from all nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident Beefree Media shall 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 sUAS, flight operations will cease immediately. All operations of sUAS shall be conducted with the permission from the land owner/controller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted. 9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance with the statutory mandate under Section 333 regarding proximity to airports. The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request. 10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his mandate. The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC to be able to use their own vision to see the sUAS in real time and space unaided by any device other than corrective lenses.

of 10 18All sUAS operations must utilize a VO. The VO may be utilized to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC and VO must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions required. The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not be conducted during night as defined in 14 CFR 1.1.

11. Petitioners should describe any procedures they would implement for conducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be completed safely. These procedures can be addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar document.

Beefree Media will conduct preflight safety risk assessments to determine that the sUAS is in a condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be completed safely. Specific procedures are addressed in the DJI-Inspire 1 Manuals and Safety Guidelines as well as the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log

.

12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations – such as motion picture and television filming, or pipeline and powerline patrol – petitioners should describe their intended coordination in this regard for their proposed operation(s).

Beefree Media does not have existing requirements for a notification to Flight Standards District Offices (FSDOs). Upon the need for an operation requiring notification to the FSDO, Beefree Media will submit a written plan of activities that will be submitted to the local FSDO in reference to the Beefree Media MPTOM at least 3 days before aerial filming. The plan of activities will include a list of the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on-scene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming;

of 11 18f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place. 13. The FAA intends to require entities who obtain an exemption under this process to also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS. The COA application is available here. Beefree Media shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this requested grant of exemption.

of 12 18Specific Regulation Requisition Exemption

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Beefree Media. LLC an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 V.S.C.§44701 (t) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from an airport and more than three miles from any densely populated area. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. The DJI Inspire 1 to be operated hereunder is less than 8 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two pounds

. 14 C.F.R. 45.23(b): Marking of the Aircraft This regulation requires certain experimental, provisionally certificated aircraft, or light-sport category aircraft to be marked with letters between 2 inches and 6 inches high “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit, or pilot station. Even though the sUAS will not have an airworthiness certificate, an exemption would be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering would be impracticable.

of 13 1814 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the sUAS to have completed sUAS flight training by reviewing each of the three DJI Inspire 1 manuals (attached to this document), review all DJI Inspire 1 tutorial videos listed at www.dji.com/product/inspire-1/video . The pilot would also perform a minimum of 200 flight cycles, 25 hours of total time as a sUAS roto-craft pilot and a minimum of 10 hours of piloting the Inspire 1 before performing the first “operational flight” under this exemption. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are mitigated from the level of risk associated with commercial operations contemplated by Part 61 allowing operations of the sUAS as requested with a pilot who has met the minimum requirements stated above exceeding the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.7(a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the DJI Inspire 1 Manuals, DJI Inspire 1 tutorials and the use of the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log prior to each flight, an equivalent level of safety will be provided. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. 14 C.F.R. 91.103(b): Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the DJI Inspire 1 Manuals. These actions as well as those required within the Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log will provide an equivalent level of safety.

of 14 1814 C.F.R. 91.109: Flight Instruction Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUASs and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and by the size and speed of the aircraft. 14 C.F.R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multi- rotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which will typically operate at altitudes of 150 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personnel all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 8 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

of 15 1814 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The Inspire 1 is limited to operations in predetermined and controlled environments, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a). The battery powering the Inspire 1 provides approximately 18 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, DJI Inspire 1 flights would not be possible. Given the limitations on the DJI Inspire 1 proposed flight area and the location of its proposed operations within a predetermined area, a time frame of 14 minutes for flight in daylight VFR conditions is reasonable allowing 25% battery power to remain upon returning to the predetermined (home) location. These restrictions will be more than adequate to return the DJI Inspire 1 to its planned landing zone from anywhere in its limited operating area. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration the regulation provides in part: (a) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current air worthiness certificate.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The DJI Inspire 1 fully loaded weighs no more than 8lbs and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display them on the DJI Inspire 1. An equivalent level of safety will be achieved by keeping these documents at the ground flight control point where the pilot flying the sUAS will have immediate access to them; to the extent they are applicable to the sUAS. 14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed 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 ... ,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Beefree Media. Maintenance will be accomplished by the PIC.

of 16 18Public Interest Beefree Media is a leading triple bottom line business solutions and marketing agency providing a valuable support and service to industry whose business model supports economic growth, environmentally sustainable solutions or mitigations, and community enhancement. Our image in the public eye locally is very well recognized and growing expediently. It is our commitment to maintain a positive image with the public by managing all operations as a concrete example in regards to safety, compliance, communication, and efficiency. Beefree Media will provide our vastly expanding local market here in South Florida a safe, well trained and professional solution based option to comply with FAA regulation while pursuing their unique sUAS needs. The applicant proposes that the exemptions requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure.

of 17 18**A Summary That Can Be Published in The** Federal Register, **Stating: The Rules From Which Beefree Media, LLC. Seeks Exemption:** 

Beefree Media, LLC seeks exemption from the requirements of 14 CFR part 21, subpart H; 14 C.F.R. 45.23(b);14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b).

**Conclusion** As set forth above, Beefree Media Solutions, LLC seeks an exemption pursuant to 14 CFR 11 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe commercial operation of the DJI Inspire 1 sUAS. By granting this Petition, the FAA will allow Beefree Media, LLC to safely, effectively and efficiently commercially operate the designated DJI Inspire 1 sUAS. Submitted on September 16, 2015 Thank you for this submission request. Sincerely,

Jared Jacobs Beefree Media, LLC 2312 N-Miami Ave Miami, FL. 33145 PH: 937-657-8031 Email: jared@beefreemedia.com

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