Perry S Bechtle, .lr 

President, FlightLife, LLC 

555 Rutile Drive, Ponte Vedra Beach, FL 32082 

November 3, 2015 

U.S. Depmtment of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

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Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part II 

of the Federal Aviation Regulations from: 

Part 45.23(b) Display of Markings 

~Pa-rt-21 subH -CertlficationproceCiures~tor products ana-parts, Airwortlli.iless Certificates 

Part 61 

Part 91 

91.1 03(b)(2) 

91.105 

91.109 

91.119 

91.121 

91.151 

91.405 

91.407 

91.409 

91.417 

Certification: Pilots, Light Instructors, and Ground Instructors 

General Operating and Flight Rules 

Preflight action 

Flight crewmembers at stations 

Flight instruction 

Minimum safe altitudes 

Altimeter settings 

Fuel requirements for flights in VFR conditions 

Maintenance required 

Operation after maintenance 

Inspections 

Maintenance records 

Dear Sir or Madam: 

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Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.F.R., FlightLife, LLC, 

--an operaioro{ an ·o nmannea7\ircraf'fSysfern· for aerial._ photogr~ph)' Nioeography forc6mri1erciarana. private 

television, print, online media, advertising, real estate, construction, and inspection interests hereby applies for 

an exemption from the Federal Aviation Regulations to allow commercial operation of it's UAS. FlightLife, 

LLC is in possession of a OJ! Phantom Vision 2 Plus, 0.11 Phantom 3, G4 Recon, OJ! Spreading Wings S I 000 

and also uses similar UAS each weighing less than 55 pounds including payload. 

The UAS operated by FlightLife, LLC \veighs less than 55 pounds, including the payload (i.e. camera, lens, and 

gimbal). It has a maximum speed of less than 87 knots, can hover, and can simultaneously move vertically and 

horizontally. FlightLife, LLC will only operate its UAS in line of sight only and will operate with pennission of 

the managing municipality, landowner and/or event organizer for which it is being operated. Operations of the 

UAS will be primarily for capturing video and photography utilized in commercial and private television, print, 

online media, advertising, real estate, construction, event and other inspection interests. The overwhelming 

majority of FlightLife, LLC photography is comprised of 2 story structures and wooded areas which would not 
usually necessitate the altitude ofthe UAS to go above 100 feet. Such operations will insure that the UAS will 

"not create a hazard to users of the national airspace system or the public." 

The Aircraft and their operation: 

This UAS has flight control using a remote control operating the 5. 728-5.85Ghz frequency in 

compliance with FCC regulations. The range extender operates within a frequency of 2412-2462MHz 

in accordance with FCC regulations. -

At any time that communication is lost the UAS will return to its take off location at a height of 

approximately 60 feet. 

The UAS locks onto multiple GPS satellites to establish a "home" position prior to flight. 

All flights will be operated within line of sight by the pilot and observer. 

Maximum flight time of each event will be limited to appx. 20 minutes or less, this will leave 

approximately 50% of reserve time on the UAS. 

Flights will be well below the 400 feet AGL requirement, FlightLife, LLC will not operate a UAS 

above 350 feet AGL. 

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view is required, who will control the recording via the 0.11 application on a smart phone or tablet. -

UAS operation will not be commenced if within 5 miles of an airport and/or whatever the most 

current UAS regulations require, which will ensure no danger to manned aircraft traffic or other 

security interests. Additionally, Notams, TFR's, FAA UAS software and other sources of airspace 

information will be referenced before every flight to ensure safety. 

Preflight procedure will be as follows: 

o Power supply test of UAS, Controller, Range Extender and 0.11 application device(smartphone) 

o Calibration of compass 

o Weather considerations 

o Flight obstructions 

o GPS lock of no less than 6 satellites 

o Link between controller and UAS 

o Link between application and UAS 

All maintenance will be conducted in accordance with all manufacturer's specifications 

All maintenance and repair/modifications will be logged in a permanent file for future reference. 

All of the latest finn ware will be updated as needed via the 0.11 software as well as controller 

calibrations. 

There is a growing demand in this area for UAS photography and media products and we can ensure that this is 

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safety and is positioned to provide these services in the safest and most professional manner possible at this time 

and in the future as the equipment and regulations evolve. The Flightlife, LLC President is an acrobatic pilot 

and fom1er US Navy Blue Angels Officer who is actively involved in aviation human factors and other aviation 

and aerospace activities. 

If you have any further questions please feel free to contact the undersigned at 904-4 72-8898 or email to 

myfl i2.htl i fc(W.gmai l.com.