Drone Productions, LLC 4 0 0Em eryDriv e, Su ite 3 0 0 Birmin g h am , AL 3 5 2 4 4 (2 0 5 ) 2 2 2-2 7 32 E-m ail - Ry an @ dro n ep ro ductio n s.co m

June 7, 2015 U.S. Department Of Transportation Docket Management System 1200 New Jersey Ave, S.E. Washington, DC 20590

REF: Exemption Request Section 333 of the FAA Reform Act

Dear Sir / Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") nd 14 C.F.R. Part 11, Dro n e Pro du ctions, LLC seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the DJI Phan t o m 3 Unmanned Aircraft System manufactured b y DJI of Shenzhen, China. The requested exemption would support an a pplication for a commercial Certificate ofAuthorization.

The exemption would permit Drone Productions, LLC to p urse its commercially the following industries / activities: 1. Construction Monitoring with Aerial Photography 2. Construction Surveying with Differential Photography Method 3. Aerial Photography for Motion Picture and Television Industry 4. Real Estate Aerial Photography 5. Product Demonstrations and Marketing

The DJIPhantom 3 system consists of a lightweight (1280 grams) battery operated aircraft, based on a small hand-held remote control operating on 2 .4 GHz and is CE and FCC compliant. In addition to the remote c ontrol, the DJI Phantom 3 offers the pilot with First Person Viewing "FPV" via integral 2.4 Ghz connection and ground control receiver. The aircraft carries an onboard video and still camera. The aircraft will be operated in the field with both a Pilot in Command (PIC) and

a ground-based Visual Observer (VO) in accordance with FAA Policy N 8 900.227 Section 14 "Operational Requirements for UAS".

Operations will o c cur under a Certificate of Authorization (COA) in accordance with FAA policy for flights at or below 200', during daytime Visual Flight Rules conditions, with a visual line of sight to the pilot, and a least 5 nautical miles from an airport with an operation control tower, at least 3 nautical miles from an airport with a publishe d i n s trument flight procedure without an operational c o n tro l tower, at least 2 nautical miles from an airport without a published flight procedure or an operational contro l t o w er , and at least 2 nautical miles from a heliport with a published instrument flight procedure. Flights requiring an additional COA f or operations outside the policy parameters listed above will be coordinated with the FAA.

The PIC will meet the requireme nts outlined in FAA Policy N 8900.227 Section 16

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. wpdPersonnel Qualifications. A dditionally, the PIC will perform maintenance on the system and will

complete a course of maintenance instruction as part of their initial training. Due to the simplicity of the system, we do not anticipate the need f or a supplemental pilot. We submit that the combination of the aircraft's light weight, h i s t o ri cally demonstrated flight performance, fully qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have confidence that the operation will have an equivalent or greater level o f safety o f manned aircraft performing the same mission.

Drone Productions, LL C is a Alabama based single entity Limited Liability Company. Dron e Productions, LLC is wholly owned by Ryan Nelson, and is a disregarded entity for the purposes of federal tax.

The regulations from which the exemption is requested are as follows: - 14 CFR Part 21 - 14 CFR 91.203 - 14 CFR 45.23, 45.29 - 14 CFR 91.9 - 14 CFR 61.113,61.133 - 14 CFR 91.11 9 - 14 CFR 91.121,91.151 - 14 CFR Subpart E (91.401- 91.417) -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

W e are prepared to modify or amend any part of this request to satisfy the need f o r an equ i v alent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarification.

Sincerely, Drone Productions

Ryan Nelson President

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. wpdEXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Drone Productions, LLC Systems requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards f or Unmanned Aerial Systems, we request an FAA Modernization and Reform Act, Section 333 Ex emption be issued for the DJI Phantom 3 sUAS under the following provisions:

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in le tt er s at l e a st 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" c an be placed, and may not have

a registration number assigned to it by the FAA. We propose to achieve an e quivalent level of safety by including the word "EXPERIMENTAL" in the p lacard on the top of the aircraft, where the PIC, VO and others in the vicinity o f the aircraft while it is preparing f or launch will be a

ble to see the designation. Additionally, w e feel that the p ermanent placard will provide the aircraft's registration information at the ground station.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regu l ati on provides that no p erson that holds a Private Pilot certificate may act as pilot in Command of an aircraft f or compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: ( 1) The flight is only incidental to that b usiness or employment; and (2) The ai rcr af t d o e s not carry passengers or property for c ompensation or hire. Our proposed operations require that the PIC must hold at least

a Pri v ate Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel w e meet the intent of 61.113 Subparagraph (b) even th o u g h th e intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no p erson may operate an aircraft unles s a current, approved flight manual is in the aircraft. We a ssume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would
not be available to the crew during f light operations. To obtain an equivalent level of safety and meet the intent of91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

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. wpdThe regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft h as f ully functioning dual controls." The sUAS System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second
set o f "controls", both the student and instructor can, and will

, o p er ate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, w e feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated c loser than 500 f eet to any p erson, vessel, v ehicle, or structure. Since the typical mission of the sUAS would be photography or surv ey of p ersons, v essels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will o nly be flown over property or persons where p ermission has been obtained and c areful pre-planned has b een performed. The aircraft wil l b e operated at a low altitude allowing, if a power unit fails, an emergency landing w ithout undue hazard
to p ersons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal c ompared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings. The re g u l ati o n requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always f ly below 600 feet AGL and will not n eed to maintain cruising altitudes in order to prevent conflict with o ther aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen held b y the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no p erson may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that f or at least 30 minutes. We feel the intention of this p aragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration o f flight from a single b attery charge is 18-25 (depending on which sUAS and method of f light) minutes with a 20%

reserve. Since the aircraft w ill never fly more than 1 NM from the point of intended landing, a f ull battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask f or an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number a ssigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." The s U A S i s t o o small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be collocated with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information f ound o n airworthiness and

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. wpdregistration certificates be permanently affixed to the aircraft via placard containing the following

information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft f or return to service." The PIC will ensure that the aircraft is in an airw o rthy c o n d i tion prior to every flight and in addition, c onduct detailed inspections after every two hours of flight. Maintenance performed b y the PIC is limited to repairing small cracks, replacing a propeller, checki n g electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer

or their designated repair facility. The PIC wil l document w ork performed in accordance with 91.417. We f

eel that due to the size, construction, and simplicity of the aircraft, the PIC c an ensure an equivalent level of safety.

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