Sam Hodde

528 Parkview

Richardson, TX 75080

214-244-3239

smhodde@att.net

12/18/2015

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform ACT of 2012 (the 

Reform ACT) and 14 C.F.R. Part 11, Hodde Visuals LLC, a photography, video and film 

production company, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UASs, so long as such 

operation are conducted within and under the conditions outlined herein or as my be 

established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive UAS under controlled conditions in airspace 

that is limited, predetermined, controlled as to access and would provide safety 

enhancements to the already safe operations in the film and television industry presently 

using conventional aircraft. Approval of this exemption would thereby enhance safety 

and fulfill the Secretary of Transportation’s (FAA Administrator’s) responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

Regulations from which the exemption is requested:

14 C.F.R. Part 21

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

14 C.F.R. 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) & (b)

14 C.F.R. 91.405

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)
This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rulemaking require under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UASs do not create a hazard to users of the NAS or the public 

or pose a threat to national security in light of the following:

o The size, weight, speed and operation capability of the UAS to be 

operated,

o Operation of the UAS in close proximity to airports and populated areas,

o Operation of the UAS within visual light of sight of the operator.

Reform Act 333 (a). Lastly, if the Secretary determines that such vehicles “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.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, that includes UASs, from the requirement that all civil 

aircraft must have a current airworthiness certificate.

Hodde Visuals LLC’s UASs are rotorcraft, weighing 55 or fewer pounds, including 

payload. They operate, under normal conditions, at a speed of no more than 50 knots and 

have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in visual line of sight. Such operations will insure 

that the UASs will “not create a hazard to users of the national airspace system or the 

public. Hodde Visuals LLC intends to use the DJI Phantom 3 UAS for the above 

mentioned aerial photography, video and film production.

Given the small size of the UASs involved and the restricted sterile environment within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by

exemption, allow commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the restricted areas in which the relevant UASs will operate, 

approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, 

and the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and 

television operations, the grant of the requested exemptions is in the public interested. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption 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 because the proposed operation represent a safety 

enhancement to the already safe movie and television filming operations conducted with 

conventional aircraft.

These limitations and conditions to which Hodde Visuals LLC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 55 pounds.

2. Flight will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights 

will be concluded at 25% battery power reserve should that occur prior to the 30 

minute limit.

4. Flights will be operated at an altitude of no more than 400 feet.

5. Minimum crew for each operation will consist of the UAS pilot and the Visual 

Observer.

6. Observer and pilot will at all times be able to communicate by voice.

7. Written and/or oral permission from the relevant property holders will be 

obtained.

8. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies.

9. If the UAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Security Perimeter and 

land.

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.