August 27 , 2015

U. S. Department of Transportation Docket Managem en t System
1200 New Jersey Ave

. Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), Uproarmedia, LLC (the "applicant"), operator of an Unmanned Ai rcraft Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to allow for commerc ial operation for aerial photography, aerial videography, pr ecision agriculture

, structure inspections

, surveying, UAS training

, and volunteer search and rescue missions

.

APPLICANT INFORMATION

Uproarmedia, LLC

PO Box 915

2816 Welhouse Dr
Kaukauna, WI 54130 jpietsch@uproarmedia.com (920) 358

- 0877

REGULATIO NS FROM WHICH THE EXEMPTION IS REQUESTED

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) and (b)

EXTENT OF RELIEF REQUESTED, AND WHY

14 CFR Part 21 subpart H The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and l imited operating area associated with the aircraftto be utilized, we request exception. In the restricted environment and under the conditions proposed

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthine ss certificate without said restrictions.

14 CFR 45.23 (b) Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to be smaller than required minimum. Understanding the importance of lettering I will mark my UAS with the largest possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required.

14 CFR 91.7 (a) As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard w ill exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided.

14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A n equivalent level of safety will be maintained by keeping the flight manual at ground control point where the pilot will ha ve immediate

access to it.

14 CFR 91.103 As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed.

Normal flight procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff d istances . An equivalent level of safety will be provided by preflight protocol to properly match the machine.

14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by t he speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

We can achieve an equivalent level of safety as achieved by current regulations because our UAS s does not carry pilot or passenger. While helpful, a pilots' license will not ensure remote control p iloting skills.

14 CFR 91.121 The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS

altitude indicator.14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration d ocuments on the aircraft. There is no room, capacity, or pilot on board to adequately manage such documents. An equivalent level of safety will be achieved by keeping these documents; to the extent they are applicable to the UAS, at the ground control poin t where pilot has immediate access

to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight.

Uproarmedia , LLC is seeking relief from all FARs above preve nting applicant from conducting commercial flights listed within this petition, operated at levels less than 400 ’ AGL , at a speed less than 50 mph, and with a maximum flight time of 30 minutes.

UAS INFORMATION

Tarot 680Pro The Tarot 680Pro is a hex copter outfitted with a 3DRobotics Pixhawk flight controller. This UAS weight varies depending on which camer a is mounted, however it never exceeds 10 pounds. The maximum speed is 33.5 mph. Du e to the requirements of the flight, this UAS will not be flown at this speed. It also has a maximum flight time of less than 30 minutes.

3DRobotics Solo

The 3DRobotics S olo is a quad copter outfitted with a 3DRobotics Pixhawk 2 flight controller. This Solo ’ s weight is 3.3 pounds and it is capable of a maximum speed of 5 5 mph . Like the 680pro, the flights that

will be conducted with this UAS will require it to be flown much slower than its maximum speed.

Please review the attached documents for further details.

S AFETY

These limitations and co nditions to which Uproarmedia, LLC agr ees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 55lb s.

2. Flights will be operated within lin e of sig ht of a PIC and/or observe r.

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

terminated at 2 5 % battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an a ltitude of no more than 4 00 ’ AGL

. 5. Minimum crew for each operation will consist of the PIC , and the Visual Observer.

6. UAS P ilot will be Pilot in Command ( P IC). If the PIC deems another o perator to be qualified with the necessary skills to be the o perator , that person c an also be designated as o perator provided they have a minimum of 20 hours of flight time with the UAS.

7. Flights will be operated at a lateral distance of at least 50 ’ from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation.8. A briefing will be cond ucted in regard to the planned UAS operations prior to each flight activity.

It will be mandatory that all personnel involved with the operational duties of the flight be present for this briefing.

9. PIC and observer will have been trained in operation of UAS generally and received up

- to

- date information on the particular UAS to be operated.

10. Observer and PIC will at all times be able t o communicate by voice, radio, and/or text.

11. Written and/or oral permission from the relevant property holders or property representatives

will be obtained.

12. If the UAS loses communication s or loses its GPS signal, the UAS will have the c apability to
return to a pre

- determined location and land autonomously.

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or
emergencies.

P UBLIC INTEREST

I believe t he increased safety achi eved by replacing manned aircraft carrying crew and flammable fuel

with small UAS s carrying no passengers, crew, or flammable fuel under the specific guidelines and procedu res proposed in this petition gives the FAA good cause to find that the UAS operations enabled by this petition are in the public interest. Furthermore , by replacing the manned a ircraft traditionally

used for the kinds of op erations proposed in this petition

, with small UAS, we will be able to pro vide aerial operations services at a greatly reduced cost, making these kinds of services available to a larg er range of businesses and consumers, thereby increasing the utilization of aerial operations and benefitting the economy as a whole. Granting Uproar m edia, LLC an exemption to operate its UAS s commercially furthers econ omic g rowth and public safety

, providi ng the FAA good cause to grant this
petition.

PRIVACY

All flights will occur over private, controlled or approved property with the property representative or

owner ’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

ATTACHED DOCUMENTS

1. 3DR_Pixhawk_User_Manual.pdf

2. 3DR_Solo_Preflight_Checklist.pdf

3. 3DR_Sol o_User_Manual.pdf

T hank you for your time and consideration.

Sincerely,

Jason Pietsch Uproarmedia, LLC