David Lee Brown

Hapa LLC 8275 S. Eastern Ave. Ste 200-815 Las Vegas, NV 89123 (702) 716-5002 hapalvnv@gmail.com

Re: Petition for Exemption Pursuant to Section 333

To Whom It May Concern:

I, David Lee Brown, am seeking exemption from the requirements to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit David Lee Brown to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography. I, David Lee Brown, have been performing traditional commercial video and photography for over 4 years, and have extensive experience with various electronic equipment, function, capabilities, and limitations. Following is a brief explanation of specific sections I am seeking exemptions:
14 CFR Part 21 — Airworthiness Certificates Due to the speed, weight, size, and limited operating area associated with the unmanned aircraft, on operation of DJI Phantom 3 Professional meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Earl D. Harrison requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

14 CFR 61.113(a) &(b) — Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138.

14 CFR Section 91.7 — Civil aircraft airworthiness Currently, the DJI Phantom 3 Professional does not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. However, David Lee Brown will ensure that the DJI Phantom 3 Pro is in an airworthy condition, prior to every flight, by determining that the UA is in compliance with the operating documents and that the aircrafts are in a condition for safe flight.

14 CFR 91.9 (b)(2) — Civil aircraft flight manual, marking, and placard requirements Due to the size of the DJI Phantom 3 Pro, there will be no pilots or passengers, as well as an aircraft flight manual within the UA. However, the owner's safety/flight manual will be located within reach of the operator.

14 CFR 91.119(c) — Minimum safe altitudes

### The operator will not fly the UA higher than 400 feet (the DJI Phantom 3 Pro has an altitude limit of 395').

Additionally, the UA will be kept in eyesight at all times and the use of an observer will always assist.

14 CFR 91.121 — Altimeter settings To achieve a level of safety, the DJI Phantom 3 Pro is equipped with an electronic GPS with a barometric
sensor.

14 CFR 91.151(a)(1) — Fuel requirements for flight in VFR conditions The DJI Phantom 3 Pro is powered by lithium polymer batteries that have a flight limit of no more than 20 minutes. 14 CFR 91.405(a) — Maintenance Required 14 CFR 91.407(a)(1) — Operation after maintenance, preventive maintenance, rebuilding, or alteration 14 CFR 91.409(a)(1) & (2) — Inspections 14 CFR 91.417(a) &(b) — Maintenance records Regarding the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) will be met because we will use trained technicians to perform maintenance, alterations, and preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in the user manual of the DJI Phantom 3 Professional. Additionally, David Lee Brown will document and maintain all maintenance records for the DJI Phantom 3 Professional will be inspected as prescribed by the user manual. Hapa LLC is a newly formed company comprised of myself, David Lee Brown, and business partner, Gilbert Sales. Hapa LLC is hired, but not limited to, take video & photo of pre-construction, progress, and post-construction projects. If the exemption request is granted to David Lee Brown to allow the flight of our unmanned aircraft (UA), we would provide an effective and efficient alternative to the use of manned aircrafts to our clients. The company is in the process of seeking DBE (Disadvantaged Business Enterprise) certification from the Nevada Department of Transportation.

Respectfully

David Lee Brown

Appendices: A— DJI Phantom 3 Pro Specifications Data Sheet