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 compan y, 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 outline d herein or as my be established by

the FAA as required by

Section 333.

As described more full y below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UAS under controlled conditions in airspace that is lim ited, predetermined, controlled as to access and would provide safety enhancements to the already safe operations in the film and television industry presentl y using conventional aircraft. Approval of this exemption would thereby enhance safet y and fulfill the Secretary

of Transportation’s (FAA Administrat or’s) responsibilities to “...establish requirements for the safe operation of such aircraft s ys tems in the national airspace sy stem.”

Regulations from which the exemption is requested:

14 C.F.R. Part 21 1 4 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 aircr aft s ys tems may operate safel y in the national airspace sy stem (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 t ypes of UASs do not create a h azard to users of the NAS or the public or pose a threat to national securit y in light of the following:

o The size, weight, speed and operation capab ility of the UAS to be operated,

o Operation of the UAS in close proximity to airports and populated areas
, o O peration 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 safel y in the national airspace s ys tem, the Secretary shall establish requirements for the safe oper ation of such aircraft in the national airspace s ys tem.
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authorit y by its terms includes exempting civil aircraft, as the term is d efined under §40101 of th e 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 spe ed of no more than 50 knots and have the capability

to hover, and move in the vertical and horizontal plane simultaneously . They

will operate onl y in visual line of sight. Such operations will insure that the UASs will “not create a hazard to users of the national airspace s ys tem or the public. Hodde Visuals LLC intends to use the DJ I 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 safet y) 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 securit y issue. Given the clear direction in Section 333 of the Reform Act, the authorit y contained in the Federal Aviation Act, and the significant public benefit, including enhanced safet y, 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 interes ted. Accordingl y, the applicant respectfull y requests that the FAA grant the requested exemption without delay

.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein appl y to civil aircraft that have the ch aracteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety t o operations under the current regulatory structure because the proposed operation represent a safet y
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 communi cate b y 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

a ppropriate 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 cas e of unpredicted obstacles or emergencies.