U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

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

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Hunt Country Aerials, LLC, seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for (1) DJI Phantom 3 quadcopter

, (1) DJI Inspire 1, and (1) DJI Spreading Wings S900 manufactured by DJI Innovations.

The requested exemption would support an appl ication for a commercial Certificate of Authorization to use the system to support aerial photography and videography. The DJI Phantom 3 (3lb) , DJI Inspire 1 (6.5lb) and DJI S900 (18lb) consist of a battery operated aircraft, a ground control station and/ a RC Controller, and associate d communications equipment. The aircrafts carry an onboard geo

referenced gimbaled camera that allows it to obtain photography and videography.

The Unmanned Aircraft System will be operated in the field with a PIC in accordanc e with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS".

The PIC holds a Federal Communications Commission (FCC) Technician “HAM” Radio License

Hunt Country Aerials, LLC respectfully requests the grant of exemption allowing to operate li ghtweight, remote controlled UAS's lawfully and safely.

Hunt Country Aerials, LLC also respectfully requests Exemption Request Section 333 from (but not limited to) the Specific Sections of Title 14 of the Code of Federal Regulations and part ll of the Fe deral Aviation. Regulations listed below.14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

The e xtent of relief Hunt Country Aerials, LLC seeks and the reason why:

Hunt Country Aerials, LLC is seeking relief from any applicable FARs which would prevent Hunt Country Aerials, LLC from conducting aerial shots of real estate , aerial mapping, events, and other possible legal flight operations. The weight of the UAS meets the definition of ''small unmanned aircraft” found in section 331 "The Reform Act”. Hunt Country Aerials, LLC seeks to operate legally as a small business that cater mostly to real estate agents. Realtors are not allowed to use UAS's or hire unless they or the person they hire, is allowed by the FAA to fly a UAS. Hunt Country Aerials , LLC would satisfy the need for safe and affordable aerial shots.

Hunt Country Aerials, LLC uses UAS that is considerably less than 55 pounds including the camera that is attached. The UAS will be used at speeds under 50 mph because of the nature of the business and the limited physical capabilities of the UAS. It is designed to hover and take p ictures. The UAS will be in accordance with flying well below 400ft.

The UAS in which Hunt Country Aerials, LLC would be using only utilizes battery power for its operations. There are no combustible fuels used in the UAS that Hunt Country Aerials, LLC us es. The maximum flight time for our particular UAS is 25 minutes battery life. It will fly no more than 20 minutes maximum at one time at one location. The amount of time the UAS will be in t he air, less than 400ft, is minimal.

A Safety system in place fo r Hunt Country Aerials, LLC UAS includes a GPS mode that allows the UAS to return home if communication is lost. Further, the GPS onboard allows the UAS to return back to its launched position if the battery life of the UAS is low.THE GROUND STATION PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAS while in the air. Additionally, the line of site of the UAS will not leave the sight of the PIC.

A radio transmitter/controller opera ted by the PIC to control the U AS while in flight;

A radio receiver receiving live video,and flight data from the on

- board camera and computer. It projects it all in one screen to the Pilot in Command

The UAS, weighing less than 20 lbs fully loaded, is powered by batteries and operates with no people on board which lowers the likelihood of death or serious bodily injury. With a small payload consisting of harmless electronics such as a camera and GPS, the UASs only purpos e is to be used as a tool to take pictures and videos.

Low level aerial photos and video from several angles are far more effective than ground based photos. Low level aerial video and pictures show the layout of properties with the advantage of seeing

mo re in one photo or short video.

Current applicants have used helicopters and small planes for this purpose but the cost of fuel, time, and emissions of such aircraft is not efficient enough for most customers to afford.

The benefits of reduced cost and i mproved efficiency of the UAS allows future customers to afford this service with a faster turnaround time at a lesser cost.

Hunt Country Aerials, LLC will not operate a UAS near airports and does not fly over crowds. Situational awareness is most importan t. The areas where Hunt Country Aerials, LLC conducts aerial photography is predetermined which allows for a controlled environment to operate safely.With allowing Hunt Country Aerials, LLC to conduct business with a light weight UAS, it could very well help the economy and benefit people in first response situations. Further, Hunt Country Aerials, LLC UAS is considerably lighter than the alternative, which is a helicopter or small plane. Currently, Hunt Country Aerials , LLC has 2 UAS which only operates off 25 minutes of battery power. Therefore, the UAS used by Hunt Country Aerials, LLC would o nly have a flight time of 5

- 20 minutes at one time. The likelihood of injury or even death with such a small unmanned aircraft, compared to an air craft flown by a person loaded with combustible fuel, is considerably low

SUMMARY:

Hunt Country Aerials, LLC is more than willing to follow the safety guidelines of the FAA Policy N 8900.227 Section 14 "Op erational Requirements for UAS ” with the appropri ate exemptions for flying a small UAS.

A

- No flight will be made with a UA Gross weight exceeding 55lbs

B

- All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, a t an airspeed of not more than 4 5 knots and no further than 3/4 NM f rom the Pilot In Charge

C

- Operations will be restricted to flights over private property with the permission of the property owner

D

- All required permits will be obtained from state and local government prior to operation

E

- The UAS will not be operat ed over densely populated areas

F

- The UAS will not be operated at air shows

G

- The UAS will not be operated over any open

- air assembly of people

H

- The UAS will not be operated over heavily trafficked roadsI

- The UAS will not be operated within 5 NM of an airport or heliport

J

- Operations will be restricted to day only and weather conditions equivalent to VFR

K

- The PIC will notify property owner about the operation and risk before the first flight at each new location;

L

- No flight may be made withou t a Pre

- Flight Inspection by the PIC before each operation to ascertain that the UAS is in a condition safe for flight (see Appendix A).

O perations above are the bare minimum safety guidelines Hunt Country Aerials, LLC will follow.

Hunt Country Aerials, L LC believes flying its UAS as a small business within the safety parameters of the FAA, can help people and promote the economy.

Respectfully,

Schuyler Knapp Hunt Country Aerials, LLC 10001 Mount Airy Road Upperville, VA 20184 ( 540 ) 454

- 5228