# Laugh

- Smore	Productions ,	LLC.

410	Mclean	Street Filley,	Nebraska	68357 (757)	262

- 8659 sheffieldjs@gmail.com www.laugh

- smore.comLaugh

- Smore	Productions ,	LLC.

410 Mclean	Street Filley,	Nebraska	68357 Phone:	(757)	262

- 8659

E

- Mail: sheffieldjs@gmail.com

Web: www.laugh

- smore.com

January 19,	2016

U.S.	Department	of	Transportation Docket	Operations West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Dear	Sir	and	Madam :

This	application	is	being	submitted	on	my	own	behalf	without	legal	council	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, Laugh

- Smore	 Productions ,	 LLC,	 operator	 of	 Small	 Unmanned	 Aircraft	 Systems	 (“SUASs”)	 equipped	 to conduct	aerial	photography	and	videography,	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation Regulations	 (“FARs”)	 to	 allow	 commercial	 operation of	 its	 SUASs,	 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

333.1.

As	described	more	 fully	below,	 the	 requested	exemption	would	permit	 the	 operation	 of	s mall,	unmanned	and relatively	inexpensive	SUAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	predetermined	and	3) controlled.	 The	 proposed	 exemption,	 if	 granted,	 would	 allow Laugh

- Smore	 Productions ,	 LLC	 to	 conduct commercial	operations	of	s mall	unmanned	aircraft	systems	(“UAS”)	meeting	or	exceeding	all	of	the	operational and	safety	requirements	Congress	has	set	forth	in	Section	333.

Laugh

- Smore	Productions ,	LLC	is disabled	veteran	owned	small	business	that	plans	to	utilize	current	technolog y capabilities	of	Unmanned	Aerial	Systems	to	offer	a	multitude	of	services,	including:

• Aerial	Surveying

• Remote	Sensing

• Event	Photography/Videography

• Agriculture	Purposes

• Real	Estate	Photography

• Aerial	Filmmaking	and	Photography

• Construction	Site Inspections	and	Monitoring

• Wildlife	and	Forestry	Monitoring

• Educational	and	Research	Operations

Statutory	 Authorit y Section	 333,	 titled	 “Special	 Rules	 for	 Certain	 Unmanned	 Aircraft	 Systems”,	 provides	 a mechanism	 for	 seeking	 expedited	 FAA	 authorization	 of safe civil	 UAS	 operations	 in	 the	 NAS. Section	 333(a) states	 that	 the	 FAA	 “shall	 determine	if	 certain	 unmanned	 aircraft	 systems	may	 operate	 safely	in	 the	 national airspace	system	before	completion	of	the	(comprehensive)	plan	and	rulemaking	required	by	Secti on	332(b)(1) of	this	Act	or	the	guidance	requir ed	by	Section	334	of	this	Act.” In	Section	332(b)(1),	Congress	made	it	clear	that Section	333	provides	a	mechanism	for	“expedited	operation	authorization”	if	several	factors	are	met.	Petitioner meets	all	requi rements	to permit	FAA	approval	of	commercial	UAS	operations.

The	Petitioner	Requests	Relief	From	the	Following: Regulations	from	which	the	exemption	is	requested:

14 C.F.R. Part	21

14	C.F.R. 45.23	(b)

14	C.F.R. 61.113(a)	and	(b)14C.F.R. 91.7	(a)

14 C.F.R. 91.9	(b)	(2)

14	C.F.R. 91.109

14	C.F.R. 91.119

14	C.F.R. 91.121

14	C.F.R. 91.151	(a)

14	C.F.R. 91.203	(a)	&	(b)

14	C.F.R. 91.205	(b)

14	C.F.R. 91.215

14	C.F.R. (91.401

– 91.417)

Unmanned	Aircraft	System

SUASs	 are	 oftentimes	 seen	 as	 superior to	 helicopters	 due	 to	 the	 smaller devices cheaper	 equipment	 and personnel	cost,	reduced	noise	and	as	such,	a	much	smaller	environmental	impact	which	promotes	public	safety.

We	 are	 petitioning	 for	 exemption	 to	 enable L augh

- Smore	 Productions ,	 LLC	 to	 operate	 a	 DJI Phantom	 3

Professional equipped	with	three

- axis	gimbals	and	using	High

- Def cameras.	This	SUAS	has	a	built

- in	capability	to limit	 the	 height	it	 flies	 above	 the	 ground,	 to	 limit	 the	 radius	 of	 the	 distance	it	 flies	 from	 the	 operator	 and	 to exclude	it	 from	 Class	B,	 C	and	D	airspace	including	a	 no	 fly	 z one	 feature.	The	 Phantom	 3 also has	 the	 failsafe

functio n	of	the	RTH	(Return	to	Home) ,	which	means	when	the	communication	between	the	Main	Controller	and the	transmitter	is	disconnected,	the	outputs of	the	command	sticks	from	controller	will	go	to	the	c enter	position.

The	GPS system	wil l	automatically	trigger	Return	to	Home	and	will	land	safely.

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

• Laugh

- Smore	Productions ,	LLC	will	only	operate	its	SUAS	in	line	of	sight	of	a	pilot	and/or	observer	and

w ill	 operate	 at	 sites	 that	 are	 a	 “sufficient	 distance”	 from	 populated	 areas	 within	 the	 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	of	the	public.”

• When	fly ing	SUAS	within	(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	operational	flight	will	be	(30)	minutes.

• Flights will	 be	 terminated	at	 25%	 battery	 power	 reserve	 should	 that	 occur	 prior	 to	 the	 (30)	minute

limit.

• The	SUAS	will	be	programmed	so	that	it	will	not	be	operated	at	an	altitude	of	no	more	than	(400)	feet AGL,	and	not	more	than	(200)	feet	above an elevated	pl atform	from	which	filming	is	planned.

• Minimum	crew	for	each	operation	will	consist	of	the	SUAS	Pilot	and	Visual	Observer.

• The	SUAS	operated	by	the	petitioner	weighs	less	than	(55)	pounds,	including	the	payload	(i.e.	camera, lens	and	gimbals).

• The	SUAS	w ill	operate	at	speeds	of	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	they	will	operate, our	SUAS	operations	adhere	to Reform	Act’s	safety	requirements.

The	 UA,	 powered	 by	 batteries,	 is	 smaller,	 lighter	 and	 more	 maneuverable	 than	 larger	 aircraft	 running	 on combustible	 fuel,	it	 operates	at	lower	altitudes	with	 no	 people	 on	 board	and	will	 thereby	 reduce	 current	 risk

levels and	 thereby	 enhance	 safety	 and	 dimi nish	 the	likelihood	 of	 death	 or	 serious	 bodily	injury.	With	 a	 small payload	and maximum	flight	time	of	only	(26 )	minutes,	this	offers	little	or	no	risk	to	national	security.Low	level	oblique	photos	and	video	 from	severa l	angles	are	 far	more	effective	 tha n ground	based	imagery	 for displaying	the	characteristics	of	large,	complex	properties	with	several	buildings	and	large	trees.	The	applicants in	 the	past	have	chartered	 (2)

- seat	 full	 sized	helicopters	 for	 this	purpose,	wh ich	has	proven	more	costly	 than many	 potential	 clients	 have	 been	 able	 to	 afford.	 The	 benefits	 of	 reduced	 cost	 and	 improved	 quality	 of presentation	from	the	UA	will	be	valuable	to	and	benefit	many	buyers	and	sellers	of	real	property.

Additionally,	 we	 r eque st	 that	 we	 be	 allowed	 to	 use our	 system	 to	 benefit	 first	 responders	 nearby	 who	might require	assistance,	including	fire	fighters,	police,	sheriff,	et	al.,	while	remaining	subject	to	all	limitations	cited	in this	application	as	we	do	so.

a. No	flight	will	be made	with	a	Gross	Weight	exceeding	(55)	pounds;

b. All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	(400)	feet	AGL,	at	an	airspeed	of	no

more	than (25)	knots	and	no	further	than	3⁄4	NM	from	the	PIC;

c. All	operations	must	utilize	a	Visual	Observer (VO).	The	VO	and	PIC	must	be	able	 to	communicate	by voice	at	all	times	during a	flight	operation ; d. Operations	 will	 be	 restricted	 to	 flights	 over	 private	 property	 with	 the	 permission	 of	 the	 property

owner;

e. All	required	permits	will	be	obtained	from	state	an d	local	government	prior	to	operation;

f. Laugh

- Smore	Productions ,	LLC	will	not	operate	over	densely	populated	areas;

g. Laugh

- Smore	Productions ,	LLC	will	not	be	operating	over	any	open

- air	assemble	of	people;

h. Laugh

- Smore	Productions ,	LLC	will	not	be	operating	o ver	heavily	trafficked	roads;

i. Laugh

- Smore	Productions ,	LLC	will	not	be	operating	within	(5)	NM	of	an	airport	or	heliport.

We	 respectfully	 request	 exemption	 from	 Section	 333	 to	 enable Laugh

- Smore	 Productions ,	 LLC	 to	 operate efficient,	limited,	low

- risk	c ommercial	SAUS	operations	for	the	activities	stated	respecting	at	all	times	the	space and	privacy	of	citizens and	property	whilst	keeping	our skies	safe.

Sincerely,

Joshua	S	Sheffield Laugh

- Smore	Productions ,	LLC sheffieldjs@gmail.com www.Laugh

- Smore.com (757)	262

- 8659EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

Laugh

- Smore	Productions ,	LLC	requests	an	exemption	 from	the	 following	regulations	as	well	as	any additional regulations	that	may	technically	apply	to	the	operation	of	the	SUAS	System:

14	CFR	Part	21.	Airworthiness	Certificates

This	part	establishes	that	procedures	for	the	issuance	of	an	airworthiness	certificate.	While	the	FAA	continues	to

work	to	d evelop	airworthiness	standards	for	Unmanned	Aerial	Systems,	we	request	an	experimental	certificate be	issued	for	the	DJI	Phantom	3	Professional under	either	or	both	of	the	following	provisions:

14	CFR 21.191	Experimental	Certificates .	Experimental	certifi cates	are	issued	for	the	following	purposes:

a. Research	 and	 Development

. Testing	 new	 aircraft	 design	 concepts,	 new	 aircraft	 equipment,	 new aircraft	installations,	new	aircraft	operating	tech niques,	or	new	uses for	aircraft.

b. Showing	 Compliance	 With	 Regulati ons. Conducting	 flight	 tests	 and	 other	 operations	 to	 show compliance	 with	 the	 airworthiness	 regulations	 including	 flights	 to	 show	 compliance	 for	 issuance	 of type	 and	 supplemental	 type	 certificates,	 flights	 to	 substantiate	 major	 design	 changes,	 and	 flights to show	 compliance	 wit h	 the	 function	 and	 reliability requirements	 of	 the	 regulations.	 Since	 the experimental	 certificate	 can	 be	 used	 for	 commercial	 purposes	 such	 as	 market	 surveys,	 sales demonstrations,	and	customer	crew	training,	we	would	expect	that	an	e xperimental	certificate	woul d permit	our	commercial	purpose as	well.	The	aircraft	will	not	carry	persons	or	property,	will	not	carry fuel,	and	will	only	fly	under	strict	operational	requirements.	Combined	with	the	UA’s	lightweight,	being constructed	primarily	of	carbon	fiber	and	plastic,	we	propose	that	the	UA	wil l	be	at	least	as	safe,	if	not safer,	 than	 a	 conventionally	 certificated	 aircraft	 performing	 that	 same	 mission.	 If	 an	 experimental airworthiness	 certificate	is	 not	appropriate	 for	 this	application,	 then	we	 request	an	exemption	 of	 14 CFR	 Part	 21,	 Subpart	 H, and	 the	 requirement	 for	 an	 airworthiness	 certificate	 in	 general,	 citing	 the equivalent	level	of	safety	outlined	in	the	previous	paragraph.

14	 CFR	 45.23	 Display	 of	 Marks;	 General	 and	 45.29	 Size	 of	 M arks. These	 regulations	 provide	 that	 each

aircraft	must display	“N”	and	 the	aircraft’s	registration	number	in	letters	at	least	(3)	inches	high.	Additionally, the	aircraft	must	display	the	work	“EXPERIMENTAL”	in	letters	at	least	(2)	inches	high	near	the	entrance	to	the cabin,	cockpit,	or	pilot	station.	The	SUAS does	not	have	an	entrance	in	which	the	word	“EXPERIMENTAL”	can	be placed,	and	may	not	have	a	registration	number	assigned	to	it	by	the	FAA.	We	propose	to	achieve	an	equivalent

level of	safety	by	including	the	word “EXPERIMENTAL”	in	the	placard	on	the	top of	the	aircraft,	as	shown	above

, where	 the	 PIC	 (Pilot	 In	 Command ),	 VO	 (Visual	 Observer)	 and	 others	 in	 the	 vicinity	 of	 the	 aircraft	 while	 it	 is preparing	 for	 launch	 will be	 able	 to	 see	 the	 designation.	 Additionally,	 we	 feel	 that	 the	 permanent	 placard

discus sed	in	 the	 previous	 paragraph	will	 provide	 the	aircraft’s	 registration	information	at	 the	ground	 station. Finally,	we	will	display	at	the	ground	station	a	high	contract	flag	or	banner	that	contains	the	words	“Unmanned

Aircraft	Ground	Station”	in	letter s (3 )	inches	high	or	greater.	Since	the	aircraft	will	operate	within	3⁄4	NM	of	the ground	station,	the	banner	should	be	visible	to	anyone	that	observes	the	aircraft	and	chooses	to	investigate	its point	of	origin.

14	CFR	61.113	Private	pilot	privileges	and	 limit ations:	Pilot	 in	Command	and	61.133	Commercial	pilot privileges	and	limitations. The	regulation	provides	that	no	person	that	holds	a	Private	Pilot	certificate	may	act as	a	Pilot	in	Command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b)	allows	a private	pilot	to	act	as pilot	in	command	of	an	aircraft	in	connection	with	any business	or	employment	if:	(1)	T he	flight	is	incidental	to that	business	or	employment;	and	(2)	The	aircraft	does	not	carry	passengers	or	property	 for	compensation	or

hire.	Our proposed	operations	require	that	the	PIC	must	hold	at	least	a	Recreational	Pilot	Certificate	issued	by the	 FAA	 and	 since	 the	 aircraft	 cannot	 carry	 passengers	 or	 property,	 we	 feel	 we	 meet	 the	 intent	 of	 61.113 Subparagraph	(b)	even	though	the	intent	of	this application	is	to	conduct	a	business.14	 CFR	 91.7	 Prohibits	 the	 Operation	 of	 an	 aircraft	 without	 an	 airworthiness	 certificate. As	 no	 such certificate	will	be	applicable	in	the	form	contemplated	by	the	FARs,	this	Regulation	is	inapplicable.

14	CFR	91.9 Civil	aircraft	flight	manual,	marking,	and	placard	requirements. This	regulation	provides	that no	person	may	operate	an	aircraft	unless	a	current,	approval	flight	manual	is	in	the	aircraft.	We	assume	that	the intent	of	this	requirement is	to	ensure	that	fl ight	manual	information	is	available	to	the	aircrew	while	operating the	 aircraft.	 We	 request	 an	 exemption	 to	 this	 requirement	 since	 the	 aircraft	 is	 not	 only	 too	 small	 to	 carry documentation,	 the	 documentation	 would	 not	 be	 available	 to	 the	 crew	 during	 fligh t	 operations.	 To	 obtain	 an equivalent	level	of	sa fety	and	meet	the	intent	of	91.9 ,	we	propose	that	a	current,	approved	SUAS	Flight	Manual must	be	available	to	the	crew	at	the	ground	station	anytime	the	aircraft	is	in,	or	preparing	for,	flight.

14	 CFR 91.109	 Flight	 Instruction;	 Simulated	 instrument	 flight	 and	 certain	 flight	 tests. The	 regulation states,	 “No	 person	may	 operate	a	 civil	aircraft	 that	is	 being	 used	 for	 flight	instruction	 unless	 that	aircraft	 has fully	 functioning	 dual	 controls.”	 The	 SUAS	 Sy stem	 ground

- based	 control	 station	 consists	 of	 a	 small	 hand

- held radio	transmitter	and	while	it	does	not	offer	a	second	set	of	“controls”,	both	the	student	and	instructor	can,	and will,	operate	the	single	set	of	controls	simultaneously.	With	both	student	an d	instructor	having	“hands

- on”	the controls	during	flight,	we	feel	that	this	technique	meets	the	intent	of	91.109	and	provides	an	equivalent	level	of safety.

14	CFR	91.119	Minimum	safe	altitudes: General.	The	regulation	states	that	over	sparsely	populated areas	the aircraft	cannot	be	operated	closer	 than	(500)	 feet	 to	any	person,	vessel,	vehicle,	or	structure.	Since	 the	 typical mission	 of	 the	 SUAS	 would	 be	 photography	 or	 survey	 of	 persons,	 vessels,	 vehicles	 or	 structures	 it	 would	 be necessary	 to	operate	cl oser	 than	(500)	 feet	 to	 the	items	listed.	Operations	will	only	be	 flown	over	property	or persons	where	permission	has	been	obtained	and	careful	pre

- flight	planning	has	been	performed.	The	aircraft will	be	operated	at	a	low	altitude	allowing,	if	a	power	uni t	fails,	an	emergency	landing	without	undue	hazard	to persons	or	property	on	the	surface.	Therefore	we	maintain	that	due	to	the	small	size	of	the	UAS,	the	hazard	to persons,	 vehicles	 and	 structures	 is	 minimal	 compared	 to	 manned	 aircraft;	 which	 should	 be	 co nsidered	 in granting	the	exemption.

14	 CFR	 91.121 Altimeter	 settings. The	 regulation	 requires	 that	 aircraft	 shall	maintain	 cruising	 altitudes	 by reference	to	an	altimeter	setting	available	within	(100)	NM	of	the	aircraft.	The	SUAS	will	always	fly	below	(4 00) feet	 AGL	 and	 will	 not	 need	 to	 maintain	 cruising	 altitudes	 in	 order	 to	 prevent	 conflict	 with	 other	 aircraft.	 An Above	Ground	Level	altimeter	measurement	above	the	launch	and	recovery	point	is	transmitted	via	radio	from

the	SUAS	on

- board	computer	to	the display	screen	held	by	the	PIC,	providing	a	constantly	updated	AGL	readout.

14	CFR	91.151	Fuel	requirements	for	flight	in	VFR	conditions. The	regulation	provides	that	no	person	may begin	 a	 flight	 in	 an	 airplane	 under	 day

- VFR	 conditions	 unless	 there	 is	 eno ugh	 fuel	 to	 fly	 to	 the	 first	 point	 of intended	 landing	 and	 to	 fly	 after	 that	 for	 at	 least	 (30)	 minutes.	We	 feel	 the	 intention	 of	 this	 paragraph	 is	 to provide	 an	 energy	 reserve	 as	 a	 safety	 buffer	 for	 delays	 to	 landing.	 The	 SUAV	 is	 battery	 operated	 and	 the

m aximum	 duration	 of	 the	 flight	 from	 a	 single	 battery	 charge	 is	 (12)	 minutes	 with	 a	 20%	 reserve.	 Since	 the aircraft	will	never	 fly	more	 than	3⁄4	NM	 from	 the	point	of	intended	landing,	a	 full	battery	charge	at	launch	will ensure	that	we	meet	the	reserve	energy requirement	of	this	paragraph.	We	request	an	exemption	to	the	word “fuel”	and	ask	for	an	equival ent	interpretation	with	the	word “energy”.

14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certification	required. The	regulation	provides	that	an	airworthiness

certifi cate,	with	the	registration	number	assigned	to	the	aircraft	and	a	registration	certificate	must	be aboard	the aircraft.	Additionally,	subparagraph	(b)	provides	that	the	airworthiness	certificate	be	“displayed	at	the	cabin	or cockpit	entrance	 so	 that	it	is legible	 to	 passengers	 or	 crew”.	At	a	maximum	gross	weight	 of	 (5.3)	 pounds,	 the SUAS	is	too	small	to	carry	documentation,	does	not	have	an	entrance,	and	is	not	capable	of	carrying	passengers or	 crew.	 To	 obtain	 an	 equivalent	 level	 of	 safety	 and	 meet	 the	 inte nt	 of	 91.203,	 we	 propose	 that	 documents deemed	appropriate	 for	this	aircraft	by	the	FAA	will	be	co

- located	with	the	crew	at	the	ground	control	station and	 available	 for	 inspection	 upon	 request.	 In	 order	 to	 identify	 the	 aircraft,	 we	 propose	 that	 the	 informa tion found	on	airworthiness	and	registration	certificates	be	permanently	affixed	to	the	aircraft	via	placard	containing the	following	information	plus	the	word	“EXPERIMENTAL”	to	satisfy	the	requirement	of	14	CFR	45.23.

14	CFR	Subpart	E	(91.401

– 91.417)

– Maintenance,	Preventive	Maintenance,	Alterations. The	regulation provides	 that	 the	 operator	 is	 primarily	 responsible	 for	 maintaining	 the	 aircraft	 in	 an	 airworthy	 condition, including	 compliance	 with	 part	 (39)	 and	 (43).	 Paragraphs	 91.407	 and	 91.409	 requir e	 that	 the	 aircraft	 be “approved	for	return	to	service	by	a	person	authorized	under	43.7” after	maint enance	and	inspection.	It	is	our intention	 that	 the	 PIC	 perform	maintenance	 and	inspection	 of	 the	 aircraft	 and	 “be	 authorized	 to	 approve	 the

aircraft	 for	r eturn	 to	service.”	The	PIC	will	ensure	 that	 the aircraft	is	in	an	airworthy	condition	prior	 to	everyflight	and	in	addition	conduct	detailed	inspections	after	every	two	hours	of	flight.	Maintenance	performed	by	the PIC	 is	 limited	 to	 repairing	 small	 cracks, replacing	 a	 propeller,	 checking	 electrical	 connections	 and	 updating

software	 and	 firmware for	 the	 on

- board	 computer.	 All other	 maintenance	 will	 be	 performed	 by	 the manufacturer	 or	 their	 designated	 repair	 facility.	 The	 PIC	 will	 document	 work	 performed	 in accordance	 with 91.417.	We	feel	that	due	to	the	size,	construction	and	simplicity	of	the	aircraft,	the	PIC	can	ensure	an	equivalent level	of	safety.

Safety	and	Benefits	of	the	UAS Laugh

- Smore	 Productions ,	 LLC	 will	 be	 using	 the	 SUAS	 in	 a	 variety	 of	 applica tions	 that	 generally	 require expensive	 full

- size	 manned	 aircraft	 to	 complete.	 Small,	 light,	 unmanned	 aerial	 vehicles	 offer myriad	 benefits

over	 the	 use	 of	 full

- sized	 manned	 aircraft	 for	 electric	 power	 line	 inspection,	 oil	 and	 gas	 pipeline	 inspection,

advan ced	 agriculture,	 film	 and	 still	 photography,	 just	 to	 name	 a	 few.	 Replacing	 significantly	 larger	 manned aircraft	carry ing crew	and	 flammable	 fuel	with	 the	small	UAS	carrying	no	passengers	 or	crew	creates	a	much greater	 margin	 of	 safety	 for	 the	 pilots	 and	 cr ew.	 By	 granting Laugh

- Smore	 Productions ,	 LLC	 requested exemptions,	 the	 FAA	 will	 help	 drive	 development	 of	 safe	 and	 successful	 commercial	 UAS	 operations	 and	 will advance	 the	 public	 knowledge	 base	 for	 such	 operations.	 Butterfuly360,	 LLC	 is	 committed	 to	 promo ting	 UAS research	efforts	of	policymakers	including	the	FAA,	NASA,	DOD	and	DARPA	by	sharing	data	from	its	commercial UAS	operations	and	serving	as	a	resource	for	future	UAS	research	operations.	Thus,	the	FAA	has	good	cause	to grant	this	Petition.

Conclusi on As	pointed	out	in	this	application,	all	the	SUASs	which	our	company	would	use,	under	authorization	by	the	US

DOT

- FAA,	are	small,	light

- weight	devices	operated	within	 the	line	of	sight	of	 the	Pilot

- in

- Command	 (PIC),	less than	(400)	 fee	above	the	ground	a nd	outside	(5)	miles	 from	any	airport,	heliport,	seaplane	base,	spaceport,	or other	location	with	aviation	activities,	unless	the	air	traffic	control	authorities	(ATC)	have	been	notified	and	have authorized	each	flight	within	a	radius	of	distance.

All	 our SUASs	 have	 proven	 capability	 for	 controlled	 flight.	 They	 are	 devices	 offered	 for	 general	 sale	 on	 the

market	around	the	world	and	have	often	been	used	as	Model	Aircraft	in	the	USA.	We	are	certain	that	the	studies conducted	until	now	by	the	FAA,	about	Secti on	332,	Public	Law	112

- 95,	2014,	have	already	provided	you	with

the	assurances	on	the	airworthiness	of	SUAs	such	as	ours.

For	 the	 foregoing	reasons,	 the	exemptions	requested	herein	should	be	granted	and Laugh

- Smore	Productions

, LLC	should	be	permitted	to conduct	small	UAS	operations	in	accordance	with	its	manuals	and	all	other	operating parameters	deemed	necessary	and	appropriate	by	the	FAA.	The	submission	of	this	application	and	it	contents	is the	best	demonstration	that	indeed	it	is	possible	to	pursue	th e	authorization	process so	that	some	SUASs	may	be used	for	legitimate	commercial	activities	and	under	reasonably	safe	conditions.