January 19, 2016

U.S. Department of Transportation

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

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

Petitioner: Wolen, LLC

103 Country Club Drive

Linwood, NJ 08221

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012, Wolen, LLC, operator of Unmanned Aircraft System DJI Phant om 2 Vision Plus, hereby applies for exemption from the listed Federal Aviation Regu lations (“FAR’s”) to allow commercial operation of its UAS, so long as the ope rations are conducted within and under the conditions outlined herein or as may be e stablished by the FAA as required by

Section 333.

We would like to formally submit for an exemption f rom part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.1 51(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) o f 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 vi deography and photography for real estate purposes and events.

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 private 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 w ould permit the operation of a UAS

under controlled conditions in the NAS that would b e a) limited, b) controlled, c) predetermined, and d) will provide safety enhanceme nts 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 nationalairspace system." As found in Exemption No. 11138 ( Trudeau) and No. 13695 (Morris),

the FAA recently approved similar use of a PHANTOM 2 UAS. We will operate a UAS, the DJI Phantom 2 VISION PLUS, which is comprised o f an unmanned aircraft (UA or Phantom), an attached 4K camera and a transportable ground station. The PHANTOM 2 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 UAS has a maximum airspeed of 16 m/s. It will be operated over various rural areas, primarily around Linwood, NJ, to augment real estate listing videos, capture event a real video and photography, and related business operations.

UAS Operating Parameters

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

• operate UAS below 300 feet and within a radius di stance of 1000 feet from the controller to aid in direct line of sight visual ob servation; • obtain permission from the owner/controller of an y vessels, vehicles and structures when operations may be conducted closer than 500 fe et 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 u ndue 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 vis ual line of sight (VLOS); • use the UAS' global positioning system (GPS) flig ht safety feature whereby it hovers and then slowly lands if communication with the rem ote control pilot is lost; • conduct all operations under the flight safety pr otocols (including posting a warning sign reading: "Attention Aerial Photography in Prog ress - Remain Back 150 feet") contained in the operating documents and will activ ely analyze flight data and other sources of information to constantly update and enh ance safety protocols; • contact respective airports if operations will b e within 5 miles to advise them of his estimated flight time, flight duration, elevation o f 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 po tential danger; • only operate in safe environments that are strict ly controlled, are away from power lines, elevated lights, airports and densely popula ted areas (defined by areas depicted in "yellow" on VFR charts and through obtaining inform ation regarding congested areas from the local Flight Standards District Office (FS DO); • conduct extensive preflight inspections and proto cols, during which safety carries primary importance (reference PHANTOM Flying Flow C hart and User Manual). Regarding UAS operational training, we have flown n umerous practice flights in remote areas as hobbyists simulating flights for future co mmercial use to gain familiarization with the characteristics of the UAS' performance un der different temperature and weather conditions. will not begin a flight unless (conside ring wind and forecast weather conditions) there is enough power to fly to the fir st point of intended landing and, assuming normal cruising speed, land the UA with 30 % battery power remaining.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 (Airwor thiness Certificates) and § 91.203(a) and (b) (Certifications required), subjec t to certain conditions and limitations, is warranted and meets the requirements for an equi valent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333 ).

We request an exemption from § 45.23 Marking of the aircraft because the UAS 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 suc h a small aircraft with dimensions smaller than the minimal lettering requirement Regardless o f this, we can mark the UAS in the largest possible (entering by placing the word "Exp erimental" on its fuselage as required by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohib its the operation of an aircraft

without an airworthiness certificate, since there i s 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) and 91.417(a) and (b) Maintenance inspections since they only app ly to aircraft with an airworthiness certificate. However, as a safety precaution we wil l perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which req uires 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 believe an equivalent level of safety will be achieved by maintaining a safety/flight manual w ith the UAS ground station.

We request an exemption from § 91.119 which prescri bes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the a ltitude of 300 feet above ground level (AGL) and will also only operate in safe area s away from the public and traffic, thus "providing a level of safety at least equivale nt to or below those in relation to minimum safe altitudes." Given the size, weight, ma neuverability, and speed of the UAS, an equivalent or higher level of safety will be ach ieved.

We request an exemption from § 91.121 Altimeter set tings as it is inapplicable since the

UAS utilizes electronic GPS with a barometric senso r.

We request an exemption from § 91.151(a) Fuel requi rements for flight in VFR

conditions. The UAV is 100% electric and two Ion ba ttery alerts are issued - per the operating documents, the UAV will be landed at the first alert Also, our flights will last only 5-10 minutes each, and the UAS has an automate d function, which results in immediate landing when a low battery is detected.Public Interest

Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business suc cess. The industry is not new. However, until recently it was conducted through th e use of costly manned aircraft, a prohibitive business activity for small companies. By granting this exemption I would be able to provide affordable services. Further, the s mall 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 wil l minimize harm to the environment economic growth by providing information to compani es and the public looking to

relocate or build in the metro areas we service. Pu blic and private events serviced by our business enhance vibrancy and add culture to the co mmunity 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 airc raft described in the operating documents, which is a quad-rotor aircraft weighing 2.8 pounds: Phantom 2 Unmanned Aircraft System.

2) The UAS will not be flown at an indicated airspe ed exceeding 50 knots. The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL)

3) The UAS will be operated within visual line of s ight (VLOS) of the Pilot in Command (PIC) at all times.

4) All operations will utilize a visual observer (V O). The UAS will 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 duratio n of the flight The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

5) The operating documents will be accessible durin g UAS operations and made available to the Administrator upon request. Any r evisions to the operating documents will be presented to the Administrator upon request

6) Prior to each flight the PIC will inspect the UA S 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 mainte nance 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 maintenan ce and alterations will be properly

documented in the aircraft records.7) Any UAS maintenance or alterations that affect t he UAS operation or flight

characteristics, e.g. replacement of a flight criti cal component, will undergo a functional test flight The PIC who conducts the functional tes t flight will make an entry in the

aircraft records.

8) The pre-flight inspection section in the operati ng documents will account for all discrepancies, i.e. inoperable components, items, o r equipment not already covered in the relevant sections of the operating documents.

9) We will follow the UAS manufacturer's aircraft/c omponent maintenance; overhaul, replacement inspection, and life limit requirements . 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 l east 10 hours logged as a UAS pilot with

a multi-rotor UAS. The PIC will also have accumulat ed and logged a minimum of 5 hours as a UAS pilot operating the same make and mo del of UAS to be used for operations. In addition to the hour requirements, t he PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currency pur poses) prior to any flight.

10) We will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenanc e, inspection, and alterations will be noted in the aircraft records, including total f light hours, description of work accomplished, and the signature of the authorized p erson returning the UAS to service.

11) Each UAS operated will comply with all manufact urer Safety Bulletins.

12) An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between insp ections.

13) Prior to operations conducted for the purpose o f aerial videography/photography and for real estate listing videos and public and priva te events and similar operations, the PIC will have accumulated and logged, in a manner consi stent with 14 CFR 61.51(b), a

minimum of 25 hours of total time as a UAS rotorcra ft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

14) Prior to operations conducted for the purpose o f aerial videography/photography and for real estate listing videos and public and priva te events and similar operations, the PIC will have accumulated and logged, in a manner consi stent 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. The PIC will accomplish 3 take-offs and landings in the preceding 90 days.

15) The PIC will not operate the UAS for the purpos e of aerial videography/photography and for real estate listing videos and public and p rivate events and similar operations, unless the PIC has demonstrated and logged in a man ner 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 maneuver s and maintaining appropriate distances from people, vessels, vehicles and struct ures.16) UAS operations will not be conducted during nig ht; as defined in 14 CFR 1.1. AII

operations will be conducted under visual meteorolo gical conditions (VMC).

17) The UAS will not operate within 5 nautical mile s of an airport reference point as denoted on a current FAA-published aeronautical cha rt

18) The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

19) If a UAS 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.

20) The PIC will abort a flight in the event of unp redicted obstacles or emergencies in accordance with the operating documents.

21) The PIC will not begin a flight unless (conside ring wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 30% battery power remai ning.

22) Before conducting operations, the radio frequen cy spectrum used for operation and control of the UAS will comply with the Federal Com munications Commission (FCC) or other appropriate government oversight agency requi rements.

23) 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 t he UAS is operating. These

documents will be made available to the Administrat or or any law enforcement official

upon request

24) The UAS will remain clear and yield the right o f way to all manned aviation operations and activities at all times.

25) The UAS will not be operated by the PIC from an y moving device or vehicle.

26) The UAS will not be operated over congested or densely populated areas.

27) Flight operations will be conducted at least 50 0 feet from all nonparticipating persons, vessels, vehicles, and structures unless: cl. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS 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 person s leave such protection and are within 500 feet of the UAS, flight operations must cease i mmediately 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 t he PIC has made a safety assessment of the risk of operating closer to those objects an d determined that it does not present anundue hazard, and; C. Operations nearer to the PIC, VO, operator trainees or essential

persons do not present an undue hazard to those per sons per § 91.119(a).

28) All operations will be conducted over private o r controlled-access property with permission from the land owner/controller or author ized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be

conducted.

29) Any incident, accident, or flight operation tha t transgresses the lateral or vertical boundaries of the operational area as defined by th e 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 any further question or inquiries, feel free to contact me at pewolownik@wolenllc.com or at (609) 432-4867. Thank you.

Best Regards,

Paul E Wolownik Comptroller / Director of Business Development

Wolen, LLC