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	wit h	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	fro m	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	th e 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	ov e r	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	a s 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	enviro nmental	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	flie s	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	fu nction	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	flig ht	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	wi thin	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

not ified	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	flig ht	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	w ill	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	vertical ly	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	Sect ion	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

Kris ten	Brumbaugh

Blackhound	Creative	Werks

328	Bluestem	Drive Elgin,	SC	29045

803

- 665

- 9136
Kristen@blackhoundcreative.com