April 20, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91. 151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Dan Johnson, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Da n Johnson , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Dan Johnson , may operate my small ultra

- lightweight unmanned aircraft system (“sUAS”) commercially in airspace r egulated by the Federal Aviation Administration (“FAA”).

As described herein I, Dan Johnson , am a photographer and videographer ; experienced in flying hobby aircraft for recreational purposes. I have added a quad

- copter 1 sUAS to my inventory equipped wi th a self

contained camera with intent for aerial photograph y and videography ; following exemption and approval by the FAA.

My, Dan Johnson ' s , exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) and comparatively inexpensive sUAS(s) in tightly controlled and limited airspace. 2 Predetermined in areas away from large public gatherings, airports and heliports for community videos

, photos and video of new and remodeled commercial buildings/projects, individual homeowner aerial photography/videography, photography and video of land dev elopments for builders, and nature photos and

videos in com pletely u npopulated areas and other community related events upon request.

Currently, similar lightweight, remote controlled sUASs are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I, Dan Johnson , have personally instilled safety protocols and controls 3 to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight sUAS's specific to photography & videography usage as I, Dan Johnson , record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting my, Dan Johnson ’ s , request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate sUASs into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [sUASs] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of sUASs for photography & videography purposes. Further I, Dan Johnson , will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Dan Johnson , respectfully request the grant of an exemption allowing me to operate ultra

- light weight, remote controlled sUASs for the purposes of acquiring aerial photos & videos, both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public hazard.

1 Supple mental File

– Phantom 2 Vision Plus (User Manual 1.6) & Appendix A 2 Appendix B

– Aeronautical Charts

3 Appendix C

- Personal Protocols and Controls

I. Contact Information:

Dan Johnson

, DSJ, LLC, 5244 Cottondale St

. SW. Wyoming, MI. 49519. Office: (626 ) 261

- 2949 Mobile: (616 ) 293

- 0158. Email: dansjohnson@gmail.com

### II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Dan Johnson Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).



### III. The Extent of relief Dan Johnson seeks and the Reason He Seeks Such Relief:
I, Dan Johnson , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 33 4, seeking relief from any currently applicable FARs operating to prevent me, Dan Johnson , contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integrat ion of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so.

My, Dan Johnson ’ s , ultra

- lightweight sUAS meets the definition of “small unmanned aircraft” as defined in

Section 331 and therefore the i ntegration of my ultra

- lightweight sUAS is expressly contemplated by the Reform Act. I would like to operate my ultra

- lightweight sUAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, pro viding direct experience and valuable information for formal regulation that can be administered uniformly to all related sUAS aerial photography & videography.

The Reform Act guides the Secretary in determining the types of sUASs that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the sUASs; whether the sUAS will be operated near airports or heavily populated areas; and, whether the sUAS will be operated by line of sight. 11 2 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Dan Johnson . My sUAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My sUAS is equipped with GPS and auto return safety technology. Weighin g less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I, Dan Johnson , consider safety as upmost importance with every flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 14 knot (15 mph). Built in safety systems include a GPS mode that allows my sUAS to hover in place when radio controls are released. With thre e modes to choose from, I utilize the GPS Mode 4 for aerial photography and videography. This is the safest, most reliable and stable mode to prevent accidents and hazards. When pilot communication is lost, the sUAS is designed to slowly descend to point of take

- off.

I do not operate my sUAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within thirty to one hundred (30

- 100) yards depending on location, conditions and weather. I am constantly on alert f or any manned aircraft (Police/Medical helicopters, etc.) and prepared to land / abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My sUAS is c apable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to fifteen (15) minutes, with an alt itude under two hundred (200) feet. I, Dan Johnson , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is twenty (20) to twenty

- five (25) minutes as tested.

I do not operate my sUAS at o r below the manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and sUAS to eliminate potential for crash, loss of control or hazards. Re serve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, which could create hazards to the public / property / manned aircraft, and have no

desire t o lose an investment. I have done scores of practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific sUAS’s performance under different temperature and wea ther conditions. A ll for the sake of safety.I, Dan Johnson , am extremely cautious when operating of my sUAS / ultra

- lightweight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b ). Given the small size and weight of my sUAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate sUASs into the national airspace system. My, Dan Johnson ’ sUAS, used in h obby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.



### IV. How Dan Johnson ’ s Request Will Benefit the Public As A Whole: Aerial photography and has been around for a long time through manne d fixed wing aircraft and helicopters. For small budget productions the expense of such aerial photograph y and videography is cost prohibitive. Only larger companies can afford to absorb such expense. Manned aircraft pose a threat to the public through the potential of a catastrophic crash. My, Dan Johns o n ' s , sUAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially f lown sUASs into the national airspace system, hence the passing of the Reform Act. Granting my, Dan Johnson ’ s , exemption request furthers the public interest thr ough academic/visual awareness of the photograph y and videography fields throughout the Grand Rapids area. My ultra

- lightweights UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra

- lightweights UAS

cra shing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial photograph y and videography captured through my battery operated ultra

- lightweights UAS's. Permitting

me, Dan Johnson , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Grand Rapids area for companies looking to use aerial photograph y and videography, both of which serve as a stimulus to the community.



### V. Rea sons Why Dan Johnson ’ s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Dan Johnson ’ s , exemp tion will not adversely affect safety. Quite the contrary, for the reasons stat ed permitting me, Dan Johnson , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for photographers and videographers for development in cooperation with

the FAA.

In addition I, Dan Johnson , submit the following representations of enhancements to current aerial photog r aphy/ videography. My sUAS weighs less than 5 pounds complete with a small ultra

- li ghtweight high quality camera; I only opera t e my sUAS below 400 feet (within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); My sUAS only operates for ten (10) to twenty (20) minutes per f light ; I la n d my sUAS prior to manufacturer recommended minimum level of battery power; I pil o t my sUAS through remote contro l only by visual line of sight ; My sUAS has GPS, a flight safety feature whereby it hovers and then slowly lands if communication with th e remote control pil ot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in rea sonably safe environment away from airports and areas with large groups of people ; I conduct extensive pr e

- flight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, D an Johnson ’ s , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of comme r cial sUAS into our national airspace system, helicopters are the primary means of aerial photography and videography. While the safety record of such helicopters is remarkably astounding, there has been incidents involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- lightweight sUAS.First, the potential loss of life is diminished be c ause sUASs carry no people on board and I only operate my sUAS in specific areas away from mass populations. Second, there is no fuel on bo a rd a sUAS and thus the potential for fire or explosions is greatly diminis hed. Third, the small size and extreme maneuverability

o f my sUAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my sUAS need not be so c lose to the objects they are focused on through the technology and use of post editing software allowing panning, tilting and zooming.

Accordingl y , my sUAS has been experimentally operated for familiarization/competency and will continue
to operate at an d above current safety levels.

VI. A Summary: The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requi rements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Dan
Johns o n ’ s , sUAS permits exemption from Part 21 because my sUAS meets (and exceeds) an equivalent

le vel of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to e x empt sUASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Dan Johnson ’, current and proj e cted sUASs meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 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. B. C. D. E. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size o f the sUASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 5 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9 565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. §

91.121 re garding altimeter set t ings is inapplicable insofar a s my sUAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are ina pplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me,

Dan Johnson . 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Re gulation require aircraft to be marked according to certain specification s . My sUASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

two

- inch lettering is diffic ult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mar k the sUASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so th at I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 14 C.F.R. § 61.113: Private Pilot Privileges and Limi tations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited

to non

- commercial operations. I, Dan Johnson , can achieve an equivalent level of safety as achieved by current Regulations becau s e my sUAS does not carry any pilots or pass engers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation o f my sUAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Dan Johnson , to opera t e my sUAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It al lows helicopters to be operated at lower altitudes in certain

condition s . My sUAS will never operate at an altitude greater than 400 AGL. I, Dan Johnson , will however

opera t e my sUAS in safe areas away from public and traffic, providing a level of safety a t least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed

o f my sUAS, an equivalent or higher level of safety will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b) : Mainte n ance Inspections. The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part andshall between required inspections, except as provided in parag raph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to

my, Dan John s on ', sUAS. However, as a sa fety precaution I thoroughly inspe c t my sUAS before and after each flight.

The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Ce rtificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area o f my sUAS permits exemption from Part 21 because my, Dan
Johns o n ’ s , sUAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legi slation permit the FAA to

e x empt sUASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My sUAS meets or exceeds

each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated b y the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft f light manual in the aircraft. As there are no pilots or passengers, and given the size o f the sUASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this

r egulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summar y, Dan Johnson seeks an exe mption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61 .113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91

. 409 ( a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Dan Johnson ', small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and aerial photograph y and videography operations. Currently, area awareness and aerial photography and videography relies primarily on the use of larger aircraft running o n combustible fuel. Posing potential risk to the public. Granting my, Dan Johnson ’, request for exemption will reduce current risk levels and thereby enhance safet y . My sUAS craft does not contain potentially explosive fuel, is smaller, lighter and more ma neuverable than conventional aircraft with much less flight time. Further, I operate at lower alt itudes and in controlled airspace eliminating potential public risk flying to and from establ i shed air fields. I, Dan Johnson , have been informally analyzing f light information and will compile safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with

the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on

- board my, Dan Johns o n ’ s , sUAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Dan Joh nson ’ s , operation o f my sUAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Dan Johnson

, respectfully request that the FAA gran t my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted,

Dan Johnson , Photographer / Videographer DSJ, LLC
5244 Cottondale St. SW Wyoming, MI. 49519