First Coast Photography Inc

Attn: Jeremy Smith 7800 Point Meadows Dr. Suite 717 Jacksonville , FL 32 256

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

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (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 CF R 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CF R 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Satellite Marketing Inc., operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, wo uld operate in the following manner:
Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.
Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.
Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

Aeri al inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.
Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.
The ability to offer training to persons individually or belonging to both private and/or public organizations that have i nterests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.

As descri bed fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe ope rations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”The name and ad dress of the appl icant is:

First Coast Photography Inc Attn: J eremy Smith , CEO/Chi ef Pilot Phone: 9 04-392-6543 Email: jeremysphd@gmail.com Address: 7800 Point Meadows Dr. Suite 717 Jacksonville, FL 32256

Regula tions from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (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 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

First Coast Photography Inc . will operate the DJI Phantom 3 Advanced , with a total weight of 1280 g or just under 3 lbs. The Diagonal size is 23.228inches . Under s till air the maximum speed is no more than 1 6m /s or 3 1.1 knots . The DJI Phantom 3 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Phantom 3 has f our motors, powered by a 4480mAh Lithium Polymer battery. The D JI Phantom 3 will be controlled with the DJ6 remote controller with an operating frequency of 2.400 GHz

– 2.48 3 GHz. The Phantom 3 also utilizes a mobile ground st ation. The UAS features a safety ‘R eturn to Home ’ function that in the event of a signal loss, the UAS will return to a preset position and land. The Return to Home feature can also be triggered manually. The remote connects to your phone or tablet, and a 720p HD view of everything your camera sees as you fly is displayed live. This immersive view s treams to you in absolute clarity, enabling safe flying. From takeoff to landing, the Phantom 3 responds to commands while automatically handling the most complex aspects of safe, stable flight.

**A ircraft and Equivalent Level of Safety** 

The se operation limitations are proposed for an equivalent or higher level of safety because operations will further enhance the safe ty of the persons and/or property using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to , whe n conducting commercial operations under the FAA issued exemptio n, include:
The UAS will weigh less than 55 lbs.
The UAS will have a maximum operating speed of no more than 50mph. Flights will be operated within line of sight of eit her the Pilot in Command (PIC) and/or Visual Observer (VO).
Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 20 % battery power reserve or 30 mi nutes of flight time whichever occurs first.
Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and /or not more than 200 feet above an elevated platform from which filming is planned.The UAS pilot will be a designated Pilot in Com mand (PIC) and hold a t least a Sport Pilot’s License al ong with a Third or

higher Class Medical Certificate. If the Satellite Marketing Inc., feels another operator to be qualified with the necessary skills to be PIC & possess a t least a Sport Pilot’s License along with a Third or higher Class Medical Certificate, that p erson may be designated PIC provided they have a minimum of 1 0 hours of flight time with the UAS. If the Satellite Marketing Inc., feels another operator to be qualified with the necessary skills to be PIC, that person may be designated PIC provided they have a minimum of 25 hours of flight time with the UAS.

A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.

Al l flights are prohibited from o ccur ring within I nstrument Flight Ru les Meteorological Conditions (I FR).
The flights will o ccur no closer than a 4 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.
If operations will be within a 4 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of fli ght and other pertinent i nformation.
The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenti ng p ersons will be allowed within 5 0 feet of the flight operation, and the radius may be reduced to 2 0 feet base d upon an equivalent lev el of safety determination . With the advanced permission of the FSDO, operations at closer range may be approved.
The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.
The PIC and VO will be able to communicate by voice, radio, and/or text at all times.
Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdicti ons, including law enforcement, fire or other appropriate governmental agencies.

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.

The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or e mergencies.
**14 C.F.R. Part 21, Subpart H: A irworthiness Certificates 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 FAR §91.203 (a) (1). Given the size and limited operating area associ ated with the aircraft to be utiliz ed by the Applicant, an exemption from Part 21 Subpart 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 author ize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis o f these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restri cted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatin g with an airworthiness certificate without the restri ctions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, an d operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.Lastly, application of these sa me criteria demonstrates that there is no credible threat to national security posed by the

UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial externa l load.
**14 C.F.R. § 45.23 (b). Marking of the A ircraft** 
The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or pr ovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required b y §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”
**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 who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensat ion or hire. Satellite Marketing Inc

. , may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC o f the UAS will ha ve a Pilot’s License along with a current Third Class or higher m edical and 10 hours UAS flight training , exceeding the current safety levels in relat ion to 14 CFR 61.113 (a) & (b), or PIC must demonstrate competency after receiving 25 hours UAS operation training. I feel the operation and limitations set forth in the FOM will equate to the safe operation of the UAS.
**14 C.F.R. §91.7(a): Civil Aircraft A irworthiness.** 
The regulation requires that no person may operate a civil aircraft unless it is in airw orthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of the manufacturers preflight safety check lists prior to each flight , an equivalent level of safety will be provided.
**14 C.F.R. § 91.9 (b) (2): Civil A ircraft Flight Manual in the A**  **ircraft.**
Section 91.9 (b) (2) provides: No person may operate a U.S.

- reg istered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings , and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.
**14 C.F.R. § 91.103: Preflight A ction.** 
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all

a ctions as stated in man ufacturers Phantom Pilot Training Guide including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
**14 C.F.R. §91.109: Flight Instruction.**

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their desi gn do not have f ully functional dual controls. Flight control is accomplished through the use of a control box thatcommunicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without

fully functional dual controls for a nu mber of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.
**14 C.F.R. §91.119: Mi nimum Safe A**  **ltitudes.**
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any r oute or altitudes prescribed for he licopters by the FAA. T h is exemption requests authority to operate UAS at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 20 0 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS 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 aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any ris k associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operatio ns of conventional aircraft that must comply with Section 91.119.
**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.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achie ved by the operator, pursuant to the safety check list and live flight data

m onitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**
Section 91.151 (a) prohibits an individual from beginning “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 cruis ing speed

– (1) During the day, to fly after that for at least 30 minutes (20 minutes if helicopter) ; or (2) At night, to fly after that for at least 45 minutes (20 minutes if helicopter) .” The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 2 0 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a p redetermined area, a longer ti me frame for flight in daylight conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only peopl e and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 2 0 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 2 0 % of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.
**14 C.F.R. §91.203 (a) and (b): Carrying Civil A ircraft Certification and Registration** 

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil a ircraft unless the airworthiness 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 UAS fully loaded w eighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is

no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these do cuments at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.
**14 C.F.R. §91.405 (a) ; 407 (a) (1) ; 409 (a) (2) ; 417(a) & (b) : Maintenance Inspections.**
These regulati ons require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribe d in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. M aintenance will be accomplished by the operator pursuant to the operating handbook. Satellite Marketing Inc., will carry out its maintenance, inspections and record keeping requirements in accordance with the Aircraft Manufacturers Information/Operators Ma nual. Maintenance, inspection and alterations will be noted in the aircraft logbook, including total flight hours, description of work accomplished and t he signature of the authorized UAS technician returning to service.

**Ad ditional Information** 
The appli cant and CEO of First Coast Photography Inc , Jeremy Smith , will act as primary PIC. Jeremy Smith currently holds a Private Pilot's Certificate . Jeremy Smith h as an in -d epth understanding of the aviation community, aviation regulations, not limited to weather limitations and airspace restrictions, as well as an understanding of safety concerns invol ved in using this technology to provide an asset to the community. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowi ng the commercial operation of the applicant’s UAS. Aerial photography and videography has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, it's expense has been cost -p rohibitive. Granting this exemption to me would allow me to provide this service at a much lower cost. The operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies looking to re locate or build in North East Florida



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**CONCLUSION**
As set forth above, First Coast Photography Inc , seeks an exemption pursuant to 14 C.F.R. 11.61 and Section 333 of the FAA Modernization and Reform Act which will pe rmit the safe operation of its UA S commercially, for the special purpose of conducting aerial photography and videography along with aerial inspections and surveys . By granting the Petition, the FAA Administrator will be fulfilling the Congressional mandat e of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing First Coast Photography Inc , to safely, efficiently, and economically operate its UA S commercially within the NAS.
Sincerely,

Jeremy Smith First Coast Photography Inc 7800Point Meadows Dr. Suite 717 Jacksonville, FL 32256