August 26th, 2015 United States Department of Transportation Docket Management System 1200 New Jersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam, I am writing concerning the FAA Modernization a nd Reform Act of 2012 (the "Reform Act") and the procedures contained in 14 C.F.R. 11. I hereby request that Dusan Harminc D.B.A. Stumpt own Media hereinafter referred to as “Stumptown Media” be exempted from the Federal Aviation Regula tions ("FARs") listed below so that Stumptown Media may operate its small unmanned aerial vehicles (“UAVs”) in commercial ai rspace regulated by the Federal Aviation Administration. Primary uses will be low altitude aerial photography and video footage for educational, agricultural, research, promotional, safety inspection, entertainme nt, and marketing purposes using the DJI Inspire 1, and Phantom 3 Professional UAVs. Dusan Harminc has been doing business as Stumptown Media as a Producer, Director and Camera Operator since 2003. In that time, safety has always been a primary concern and Stumptown Media has never had an accident, injury or any other safety incident of any kind. Stumptown Media intends to contin ue this record of safety when utilizing UAVs, take every measure possible to insure safe flight, contract experienced pilots as PICs, have a dedicated Visual Observer on each flight, secure permission from any people bein g filmed and property owners/ administrators above which flights take place, adhere to all FAA rules a nd regulations as well as any conditions set in the 333 exemption. For the reasons stated below, Stumptown Media res pectfully requests a grant of an exemption. Best Regards,

Dusan Harminc d.b.a. Stumptown Media 08/26/2015Table of Contents:

1. Contact Information 2. Proposed UAVs to be used 3. Proposed Commercial Use 4. Increased Safety and Public Interest 5. Compliance with FAA Ru les and Restrictions 6. Privacy 7. National Security 8. Specific Sections of Title 14 from which exemption is sought 9. Qualification for Approval 10. User Manuals with features for proposed UAVs 11. Summary

1. Contact Information: Dusan Harminc d.b.a. Stumptown Media 1254 Van Buren Avenue Saint Paul, MN 55104 (608) 698-3326 e-mail: support@stumptownmedia.com

2. Proposed UAVs to be used Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11 Stumptown Media hereby seeks an exemption from the Federal Aviation Regulations detailed below for use with the following UAVs: A. UAV Model 1: DJI Inspire 1 A lightweight UAV with a 7.5 lb. gross weight including all onboard equipment, to be used with a 3 person ground team: - A Qualified Pilot in Command controlling the UAV, - A Visual Observer providing additional safety - A Gimbal/ Camera operator using a separate contro ller from the PIC to control the camera only

Please see attached Exhibit 1- The DJI User Manual

B. UAV Model 2: DJI Phantom 3 Professional A lightweight UAV with a 4.5 lb. gross weight including all onboard equipment, to be used with a 2 person ground team: - A qualified Pilot in Command contro lling all aspects of the UAV, - A Visual Observer providing additional safety

Please see attached Exhibit 2- The DJI Phantom 3 Professional User Manual3. Proposed Commercial Use The proposed commercial uses Stum ptown Media would like to conduct using the mentioned UAVs will be low altitude aerial photography and video footage for ed ucational, agricultural, real estate, research, promotional, safety inspection, entertainment, and marketing purposes. Stumptown Media believes this application is similar to other previously granted 333 exemptions to companies in the same field as Stumptown Media an d that the grant of this exemption to Stumptown Media is in the Public Interest. 4. Increased Safety and Public Interest Stumptown Media believes UAVs are safer than full scale helicopters traditionally used for the types of commercial uses being suggested in this request. T heir light gross weight, ba ttery operation (lack of combustible fuels), maneuverability, limitation to f lights under 400 feet AGL and operation without people on board all increase the overall level of safety in the National Airspace System. In addition the proposed use for building safety inspecti ons at construction sites at a more competitive price point than traditionally available using helicopt ers will increase the overall use of such safety procedures as well as minimize the number of accidents and fatalities occurring with helicopter or climber inspection teams in the construction indust ry. The reasons mentioned above combined with environmental advantages of UAVs to use of helicopte rs, make the grant of this exception in the public interest. Additionally, the progression of the Arts and Scienc es has been fundamental to our society since its inclusion in the United States Constitution. Stum ptown Media believes that Congress mandated the integration of UASs into our natio nal airspace system, in part, to ac hieve progression in this field and Stumptown Media’s interest in aerial data capture w ill benefit the public as a whole by including our content in various Art and Science related projects.

5. Compliance with FAA Rules and Restrictions Stumptown Media considers safety and compliance wi th all applicable FAA Rules and Restrictions of upmost importance. In addition to following all ru les dictated by N.8900.227 and any Restrictions, Conditions and Limitations set forth by the potentia l 333 exemption Stumptown Media seeks with this request, Stumptown Media also plans to follow the development of new laws and regulations and continually keep up with the changes in this field.

6. Privacy All proposed uses will occur over public or controlled ac cess property with t he property owner’s or administrator’s prior consent and knowledge.7. National Security No national security issue will be ra ised by the grant of this exempti on. Given the size, load carrying capacity, speed at which they operates, and the fact that they carry no explosives or other dangerous materials, the UAVs proposed for use pose no threat to national security.

8. Specific Sections of Title 14 from wh ich Stumptown Media requests exemption Stumptown Media hereby respectfully requests exemption from the following regulations as well as any additional regulations that may apply to opera ting the abovementioned UAVs for the abovementioned commercial purposes:

I. 14 C.F.R. Part 21, Subpart H and 14 C.F.R. §91.203(a)(1) II. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a) III. 14 C.F.R. § 61.113 (a) and (b) IV. 14 C.F.R. § 91.9(B)(2) V. 14 C.F.R. § 91.7(a) VI. 14 C.F.R. § 91.103 VII. 14 C.F.R. § 91.109(a) VIII. 14 C.F.R. § 91.119

IX. 14 C.F.R. § 91.121 X. 14 C.F.R. § 91.151(a) XI. 14 C.F.R. §§ 91.203(a) and (b) XII. 14 C.F.R. §§ 91.405(a)(l); 91.407(a)(l ); 91.409(a)(l); 91.417(a) and (b)

I. 14 C.F.R. Part 21, Subpart H: Airworthine ss Certificates and 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1). Given the size and limited operating area associated with the UAVs to be utilized by Stumptown Media, an exemption from Part 21 S ubpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness cert ificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular aircraft. In all cases, an analysis of these criteria demonstrates that the UAVs operated without an airworthiness certificate in the restricted envir onment and under the conditions proposed will be at least as safe, or safer, than a conventional airc raft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAVs to be operated hereunder are less than 55 lbs. fully loaded, carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively within a designated area.Unlike other civil aircraft, operations under th is exemption will be tightly controlled and monitored by both the operator and under the requir ements and in compliance with local public safety requirements. These safety enh ancements provide a greater degree of safety to the public and property owners than convent ional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstra tes that there is no credible threat to national security posed by the proposed UAVs, due to their size, speed of operation, location of operation, lack of explosive materials or flamma ble liquid fuels, and inability to carry a substantial external loads.

II. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Ai rcraft Marking and Identif ication Requirements This petition seeks an exemption from the aircraft marking and identification requirements of14 C.P.R. §§ 91.9(c), 45. 23(b), and 45.27(a). Exemption from § 45.23(b) is needed because the proposed UAVs have no ent rance to the cabin, cockpit or pilot station where the registration number would be placed. Given the size of the UAVs 2 inch lettering is also impossible.

Because of the nature of the relie f sought by this exemption reque st, Stumptown Media requires relief from the associated marking and identification requir ements of§ 45.27(a) and § 91.9(c), which would require compliance with§ 45.23(b). An equivalent level of safety will be achieved by Stumptown Media by marking the fuselage as required by § 45.29(f) where the pilot, observe r, and others working with the UAV will see the identification of the UAV as "Experimental." Stumptown Media will also ensure compliance with any additional requests of UAV marking by the FAA.

III. 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations : Pilot in Command Pursuant to 14 CFR § 61.113 (a) & (b), no person wh o holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying pa ssengers or property for compensation or hire. The proposed UAV uses can achieve an equivalent level of safety as achieved by current Regulations because Stumptown Media’s UAVs do not carry any pilots, passengers or property. The risks attendant to the operation of suggeste d UAVs is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAVs will be, a qualified experienced Pilot and it is believed that the ope ration and limitations set forth in the operations manuals will equate to the safe operat ion of the UAVs proposed for use.IV. 14 C.F.R. § 91.9(B)(2): Civil Aircra ft Flight Manual in the Aircraft An exemption from 14 C.F.R. § 91.9(B)(2) is he reby requested because t he proposed UAVs, given their size and configuration have no ability or pl ace to carry a flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manu al at the ground control point where the pilot in command of the U AVs will have immediate access to them.

V. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness ce rtificate issued for t he UAVs for whose use we seek an exemption, should this exemption be grant ed, no FAA regulatory standard will exist for determining airworthiness. Given the size of the UAVs and the requirements co ntained in the Manual for maintenance and use of safety checklists prior to each flight, an equi valent level of safety will be provided.

VI. 14 C.F.R. § 91.103: Preflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. Since FAA approved rotorcraft flight manuals w ill not be provided for the UAVs in question an exemption will be needed. Stumptown Media will achi eve an equivalent level of safety by having the Pilot in Command take all actions as stated in the operations manual for normal procedures of the UAVs, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of each flight.

VII. 14 C.F.R. § 91.109(a): Flight Instruction Section 91.103 provides that no person may op erate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The UAVs proposed for use via this exemption by their design do not have fully functional dual controls. Flight control is accomp lished through the use of a control box that communicates with the aircraft via radio communications. Given the size and speed of the UAVs, an equivalent level of safe training can still be performed without dual controls because no pilot or passe ngers are aboard the UAVs, and all persons will be a safe distance away should the UAV experience any difficulties during flight instruction. The FAA has approved exemptions for flight traini ng without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft.VIII. 14 C.F.R. § 91.119: Minimum Safe Altitudes

This Section prescribes the minimum safe altit udes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. Section § 91.119(d)(l) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without haz ard to persons or property on t he surface," provided that "each person operating the helicopter complies with any ro utes or altitudes specifically prescribed for helicopters by the FAA.

To achieve the intended uses for which this exem ption is being sought, the UAVs, will need to be at times operated less than 500 feet away from persons, vessels, vehicles, or structures. The equivalent level of safety will be achieved giv en the size, weight, and speed of the UAVs as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with airc raft or rotorcraft weighting far more than the maximum of the UAVs proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently pres ented with conventional aircraft operating at or below 500 AGL. Furthermore, by operating at lowe r altitudes, the UAVs will not interfere with other aircraft that are subject to the minimum safe altitude regulations.

IX. 14 C.F.R. § 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set to the elevation of the departure airport or an appropriate altimeter setting available before departure. Since the UAVs proposed do not have a barometric altimeter, but instead a GPS altitude read out, an exemption is requested. An equivalent level of safety will be achieved by following the procedures set forth in the UAVs Manuals. The operator will confirm the altitude of t he launch site shown on the GPS altitude indicator before flight. Prior to each flight, the PIC will reset the altimeter to zero and will fly the UAV below 400 feet AGL. Additionally, the Pilot in Command will use the GPS altitude indicator to constantly monitor the UAV height, thus ensuring safe altitudes.

X. 14 C.F.R. § 91.151(a): Fuel Requirem ents for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginni ng a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions ) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed: (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.Since the battery powering the suggested UAVs la sts less than 30 minutes, an exemption from this requirement is requested. An equivalent level of safety will be achieved by limit ing flights to 18 minutes or 30% of battery power, whichever happens first. This restriction would be more than adequate to return the UAV to its planned landing zone from any point within its plann ed operating area. Operation of the UAVs with less than 30 minutes of reserve power does not eng ender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAVs. Additionally, all flights will be limited to controlled areas where permission to perform UAV services has been obtained and all concerned parties given notice. Stumptown Media believes that an exemption from 14 C.F.R.§91.151(a) falls within the scope of prior exemptions.

XI. 14 C.F.R. §§ 91.203(a) and (b): Carrying Civi lian Aircraft Certific ation and Registration This regulation provides in pertinent part: Except as provided in § 91.715, no person may oper ate a civil aircraft unless it has within it the following: An appropriate and current ai rworthiness certificate. No person may operate a civil aircraft unless the airw orthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAVs proposed for use fully loaded weigh we ll under the 55-lb limit and are operated without an onboard pilot. As such, there is no ability or place to carry certification and r egistration documents or to display them on the UAVs. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot in command of the UAV will have im mediate access to them, to the extent they are applicable to the UAVs in question.

XII. 14 C.F.R. § 91.405(a)(l); 91.407(a)(l); 91.409(a)(l ); 91.417(a) and (b): Maintenance Inspections These regulations specify maintenance and inspection standards in reference to 14 C.F .R. Part 43. An exemption to these regulations is requested be cause Part 43 and the stated sections apply only to aircraft with an airworthine ss certificate, which the UAVs proposed for use will not have. Equivalent level of safety will be achieved by ma intenance and insp ections that will be performed in accordance with the Aircraft Operations Manual. Th e Pilot in Command will ensure that the UAVs are in full working condition prior to every fligh t, oversee and assist in performance of required maintenance, and keep a log of maintenance performed.If mechanical issues arise, the UAVs can land immediately and will be operating from no higher than 400 feet AGL. Moreover, the UAV's small size, carr ying capacity, and the fact that flight operations will only take place in restricted areas for limited periods of time, create less risk than the same factors associated with conventional fixed-wing airc raft and rotorcraft performing the same operation.

9. Qualification for approval under section 333 of the reform act A. Stumptown Media’s proposed us age does not create a hazard to users of the NAS or the public because of the reduced size, weight, speed and operational capab ility of the UAVs proposed for use. The proposed operations would permit use of small U AVs under controlled conditions in airspace that is limited, predetermined, has c ontrolled access, and would pose an increased level of safety compared to what exists when the proposed servic es are completed by manned, full size aircraft. Stumptown Media’s UAVs weigh less than 50 pounds including payload. Stumptown Media’s UAVs operate at a speed of no mo re than 25 knots and have the capability to hover and move in vertical and horizontal planes simultaneously. Such operations insure that the proposed use will not create a hazard to users of t he National Airspace System or the public given the small size of the UAVs involved and the en vironments within which they will be used.

B. The Petitioner's Proposed Usage Does not Create a Hazard to Users of the NAS or the Public because the Operation of the UA V will be conducted in Controlled or Sterile Locations, Away from Airports and in Unpopulated Areas. Stumptown Media’s proposed usage does not create a hazard to users of the NAS or the public because the UAV's shall be flown on Private Proper ty after permission is secured from the Landlord or Agent. All concerned parties will be given notice prior to t he operations.

C. The Petitioner's Proposed Usage Does not Cr eate a Hazard to Users of the NAS or the Public because Operation of UAVs will be conduct ed within visual line of sight of the Pilot in Command or the Visual Observer at all Times. Stumptown Media will not utilize visual aids othe r than prescribed glasses or contact lenses. Stumptown Media’s will for each flight:

- Determine the UAV's proximity to all aviation activities (and other hazards)

- Exercise effective control of the UAVs

- Prevent the UAV's from creating a collision hazard

- Utilize a visual observe r who will inform the Pilot in Command before losing sufficient visual contact with the UAVsD. The UAVs will remain below 400 AGL at all times during the proposed uses. Stumptown Media’s UAVs will not fl y above 400 AGL at any time. Stumptown Media will take off, operate and land the UAVs from the ground level.

10. User Manuals with features for proposed UAVs The user manuals and support documentation for the U AVs proposed for use are available on line via the links below. Stumptown Media intends to fo llow all Manufacturer Recommendations for use and maintenance.

A. UAV Model 1: DJI Inspire 1

User Manual: download.dji-innovations.com/downloads/insp ire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

Maintenance Manual: download.dji-innovations.com/downloads/insp ire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf Manufacturer Recommended Safety Guidelines: download.dji-innovations.com/downloads/insp ire_1/en/Inspire_1_Safety_Guidelines_en.pdf Intelligent Flight Battery Safety Guidelinesdownload.djiinnovations.com/downloads/inspire_1/en/Intelli gent_Flight_Battery_Safety_Guidelines_en.pdf

B. UAV Model 2: DJI Phantom 3 Professional

User Manual:download.djiinnovations.com/downloads/phantom_3/en/P hantom_3_Professional_User_Manual_v1.4_en.pdf Manufacturer Recommended Safety Guidelines: download.dji-innovations.com/downloads/phant om_3/en/Safety_Guidelines_Disclaimer_en.pdf Intelligent Flight Battery Safety Guidelineshttp://download.djiinnovations.com/downloads/phantom_3/en/Intelli gent_Flight_Battery_Safet y_Guidelines_en.pdf11. Summary Given the before mentioned and in accordance with language in Section 333 of the Reform Act, Stumptown Media hereby respectfully requests exemption from the following regulations as well as any additional regulations that may apply to operating the abovementioned UAVs for the abovementioned commercial purposes: I. 14 C.F.R. Part 21, Subpar t H and 14 C.F.R. §91.203(a)(1) II. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a) III. 14 C.F.R. § 61.113 (a) and (b) IV. 14 C.F.R. § 91.9(B)(2) V. 14 C.F.R. § 91.7(a) VI. 14 C.F.R. § 91.103 VII. 14 C.F.R. § 91.109(a)

VIII. 14 C.F.R. § 91.119 IX. 14 C.F.R. § 91.121 X. 14 C.F.R. § 91.151(a) XI. 14 C.F.R. §§ 91.203(a) and (b) XII. 14 C.F.R. §§ 91.405(a)(l); 91.407(a )(l); 91.409(a)(l); 91.417(a) and (b)

Please contact Dusan Harminc d.b.a. Stumptown Media at support@stumptownmedia.com or at 608.698.3326 with any questions. Best Regards,

Dusan Harminc d.b.a. Stumptown Media 08/26/2015