April	20,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue	SE

Washington,	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam:

This	petition	is	being	submitted	on	our	behalf	with	legal	counsel	or	consulting	

services.

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

Reform	Act)	and	14	C.F.R.	Part	11,	Blackhound	Creative	Werks,	a	design	and	

photography	studio	company,	hereby	applies	for	an	exemption	from	the	Federal	

Aviation	Regulations	(FARs)	listed	below	to	allow	operation	of	our	Small	Unmanned	

Aircraft	System	(sUAS)	commercially	in	airspace	regulated	by	the	Federal	Aviation

Administration	(FAA)	so	long	as	such	operations	are	conducted	with	and	under	the	

conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	

Section	333.

The	requested	exemption	would	permit	Blackhound	Creative	Werks	to	pursue	its	

commercial	interests	in	providing	services	to	clients	using	a	small	advanced	sUAV	in	

the	following	areas:

• Real	Estate

• Marketing

• Special	Events

Blackhound	Creative	Werks	states	that	all	sUAS	flights	will	occur	over	private	or	

controlled	access	property	and	will	do	so	with	the	property	owner’s	consent	and	

knowledge	and	that	only	people	who	have	consented	or	otherwise	agreed	to	be	in	

the	area	where	videography	will	take	place.	
Regulations	from	which	exemption	is	requested:

14	C.F.R.	Part	21

14	C.F.R.	45.23

14	C.F.R.	91.7

14	C.F.R.	91.9

14	C.F.R.	91.109

14	C.F.R.	91.119

14	C.F.R.	91.121

14	C.F.R.	91.151

14	C.F.R.	91.203

14	C.F.R.	subpart	E	91.401-91.417

Unmanned	Aircraft	System

sUAVS	are	often	as	seen	as	superior	to	helicopters	as	an	aerial	gathering	platform	

due	to	the	smaller	devices,	cheaper	equipment	and	personnel	cost,	reduced	noise,	

and	much	smaller	environmental	impact	which	promotes	public	safety.

Blackhound	Creative	Werks	is	petitioning	for	an	exemption	to	operate	a	DJI	

Phantom	2	Vision	Plus	with	a	built-in	stabilized	HD	camera	and	GPS	safety	features	

which	limit	it’s	ability	to	limit	the	height	it	flies	above	ground	level	(AGL).,	to	limit	

the	radius	of	the	distance	it	flies	from	the	operator	and	to	exclude	it	from	operations	

within	designated	Class	B,	C,	and	D	airspace	including	a	no-fly	zone	feature.		The	DJI	

Phantom	2	Vision	Plus	also	has	a	failsafe	function	that	is	triggered	in	the	even	

communication	is	lost	between	the	sUAS	and	the	main	controller	transmitter.		At	

that	time,	the	sUAS	will	return	to	its	point	of	takeoff	and	land	safety.		If	the	

connection	is	restored,	the	PIC	can	regain	control	of	flight	and	land	manually.

These	specifications	meet	with	the	Model	Aircraft	Operating	Standards	as	set	below:

The	petitioner	will	only	operate	its	sUAS	in	line-of-sight	of	a	pilot	and	will	operate	at	

sites	that	are	sufficient	distance	from	populated	areas	within	a	sterile	area	

described	in	the	FOPM.		Such	operations	will	ensure	that	the	sUAS	will	“not	create	a	

hazard	to	users	of	the	national	airspace	system	or	the	public.”

When	flying	the	sUAS	within	five	(5)	miles	of	an	airport,	airport	operators	will	be	

notified	and	the	operator	will	give	the	right	of	way	to	avoid	flying	in	the	proximity	of	

full-scale	aircraft.

Maximum	flight	time	for	each	operation	will	be	30	minutes.

Flights	will	be	terminated	when	battery	levels	reach	25%,	allowing	sufficient	

reserve	flight	time	to	safely	land	the	sUAS.

The	sUAS	will	be	programmed	so	that	it	will	not	be	operated	at	an	altitude	that	

exceeds	400	fee	AGL,	and	not	more	than	200	feet	above	an	elevated	platform	from	

which	videography	is	planned.

Minimum	crew	for	each	operation	will	consist	of:	sUAS	pilot

The	sUAS	operated	by	the	petitioner	weighs	less	than	25	pounds,	including	all	

payload	(ie:	camera,	lens,	&	stabilized	gimbal).
The	sUAS	will	operate	at	speeds	no	more	than	50	knots,	can	hover,	and	can	

simultaneously	move	vertically	and	horizontally.	

Given	the	small	size	of	the	sUAS	and	the	restricted	sterile	environment	within	which	

it	will	operate,	Blackhound	Creative	Werks’	operations	adhere	to	the	Reform	Act’s	

safety	requirements.	

We	respectively	request	exemption	under	Section	333	to	enable	Blackhound	

Creative	Werks	to	operate	efficient,	limited,	low-risk	commercial	sUAS	operations	

for	the	activities	stated	respecting	at	all	times	the	space	and	privacy	of	citizens	and	

property	while	keeping	airspace	safe.

Sincerely,

Kristen Brumbaugh 

Kristen	Brumbaugh

Blackhound	Creative	Werks

328	Bluestem	Drive

Elgin,	SC	29045

803-665-9136

Kristen@blackhoundcreative.com