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January 6 th , 2016 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b) Dear Sir or Madam: Pursuant to Section 333 of the FAA Moderni zation and Reform Act of 2012 (the Reform Act) and 14 C.F .R. Part 11, Beavercreek Aerial Solutions , developer and operator of Small Unmanned Aircraft Sy stems (“sUASs”) equipped to conduct aerial photography , hereb y 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 b y the FAA as required b y Section 333.
As described more f

ull y below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safet y enhancem ents to the already safe operations in the film and television industry presentl y using conventional aircraft. Approval of this exemption would thereb y enhance safet y and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilitie s to “...establish requirements for the safe operation of such aircraft sy stems in the national airspace s ys tem.” Section 333(c) of the Reform Act. The name and address of the applicant is: Beavercreek Aerial Solutions Attn: Samuel Bry an Ph: 937

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- 6895 Email: sambry an1 @gmail.com Address: 2423 Rollingview Ave . Beavercreek, OH 45431 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8

- Issue a Certificate of Waiver for Motion Picture and Television Filming.1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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January 6 th , 2015 Page Two Regulations from which the exemption is requested:
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft s ys tems may operate safely

in the national airspace sy stem (NAS) before completion of the rulem aking required under Section 333 of the Reform Act. In making this deter mination, the Secretary

is required to determine which ty pes of UASs do not create a hazard to users of the NAS or the public or pose a threat to national securit y in light of the following: • The UAS’s size, weight, speed, and operational capability ; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333 (a). Lastly , if the Secretary determines that such vehicles “may operate safel y in the n ational airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace sy stem.” Id. §333(c) (emphasis added) The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authorit y by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that a ll civil aircraft must have a current airworthiness certificate.1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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January 6 th , 2015 Page Three Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Adm inistrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. The Administrator may

grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or an y s ections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1 ). Beavercreek Aerial Solutions sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They

operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously . They will operate onl y in line of sight and will operate onl y within the sterile area described in the Confidential Motion Picture and Television Operations Manual, attached as Exhi bit 1 (hereinafter “the Manual”) . Such operations will insure that the sUAS will “not create a hazard to users of the national airspace sy stem or the public.” Given the small size of the sUASs involved and the restricted sterile environment within which they

will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately . Also due to the si ze of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority

contained in the Federal Aviatio n Act, as amended; the strong equivalent level of safet y surrounding the proposed operations, and the significant public benefit, including enhanced safety , reduction in environmental impacts, including reduced emissions associated with allowing UASs fo r pictures and television commercial operations, the gr ant of the requested exemptions is in the public interest. Accordingly , the applicant respectfull y requests that the FAA grant the requested exemption without delay

. AI RCRAFT AND EQUIVALENT LEVEL OF S AFETY The applicant proposes that the exemption requested herein appl y to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of saf et y to operations under the current regulatory

structure because the proposed operations represent a safet y enhancement to the1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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January 6 th , 2016 Page Four alread y s afe movie and television filming operations conducted with conventional aircraft. These limitations and conditions to which Beavercreek Aerial Solutions agrees to be bound when conducting commercial operations under an FAA issued exemption include: The Motion Picture Association of America has reviewed this manual and has found it to be acceptable for sUAS filming operati ons for the television industry . Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary information that the applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et.seq. Reform Act Section 333 (b). Page Four 1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minut es. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 4 0 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the sUAS Pilot and a Visual Observer. 6. sUAS pilot will be an FAA licensed airman with at lea st a private pilot part 141 ground school certificate and third class medica l. The observer will hold at least a third class medical. 7. sUAS Pilot will be Pilot in Command (PI C). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC. 8. The UAS will only

operate within a confined “Sterile Area” as defined in the Manual. Section H, I and J of the Manual requires the establishment of a “Security Perimeter” f or the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day ’s production activities. It will be mandatory that all personnel who will be performing duties within the boundaries o f the safet y perimeter be present for this briefing. 10. The operator will file a FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office. 11. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation,1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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January 6 th , 201 6 Page Five and this radius may

be reduced to 30 feet based upo n an equivalent level of safet y determination, as required by Section K of the Manual. With the advanced permission of the relevant FSDO, operations at closer range can be approved. 12. The operator will submit a written Plan of Activities to the FSDO three day s before the proposed shoot as required in Section K of the Manual. 13. Pilot and observer will have been trained in operation of UAS generally and received up - to
- date informat ion on the particular UAS to be operated as required Sections M and N of the Manual. 14. Observer and pilot will at all times be able to communicate by voice and/or text. 15. Written and/or oral permission from the relevant propert y holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, count y or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. If the sUAS loses communication s or loses its GPS signal, the UAS will have capability to return to a pre
- determined location within the Security Perimeter and land. 18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergenc ies. 19. The sUAS will have an emergency parachute in the case of a failed flight for landing and recovery as well as safety The sUAS we will be using the is the DJ I Phantom 3 Professional.
**14 C.F.R. Part 21, Subpart H: Airworthiness 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 associated with the aircraft to be utilized 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 Aviati on 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 certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airpo rts and populated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS 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, and operates1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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exclusively

within a secured area as set out in the Manual. Unlike other civil aircraft, operations January 6 th , 2016 Page Six under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safet y requirements, to provide securit y for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safet y enhancements, which alread y appl y to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safet y to the public and propert y owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same 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 Aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the registration number is display ed 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 pl aced. Given the size of the sUAV, 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 safet y will be provided b y having the sUAV marked on its fuselage as required b y §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A

. **14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.** Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry

a pilot or passengers, the proposed operations can achieve the equivalent1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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level of safety

of current operations by

requiring the PI C operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to o perate this small UAS. Unlike a January 6 th , 2016 Page Seven conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safet y provided b y the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional airc raft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safet y achieved b y 14 C.F.R. §61.113 (a) & (b). **14 C.F.R. §91.7(a): Civil aircraft airworthiness.** The regulation requires that no person may operate a civil aircraft unless it is in airworthy 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 and the requirements contained in the Manual fo r maintenance and use of safety

check lists prior to each flight, as set forth in Sections J, Land Q, an equivalent level of safety

will be provided. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.** Section 91.9 (b) (2) provides : No person may

operate a U.S.

- registered civil aircraft ... 0 (2) For which an Airplane or Rotorcraft Flight Manual is not required b y §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 an y combination thereof. The sUAS, 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 pi lot on board, but because there is no room or capacit y to carry such an item on the aircraft. The equivalent level of safet y will be maintained by keeping the flight manual at the ground control point where the pilot fly ing the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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January 6 th , 2016 Page Eight **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. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safet y will be provided as set forth in Sections J and K of the Manual. The PIC will take all actions including 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. sUASs and remotely piloted aircraft, by

their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training with out fully

functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided b y the fact that neither a pilot nor passengers will be carried in t he aircraft and b y the size and speed of the aircraft. **14 C.F.R. §91.119: Minimum safe altitudes** 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 route or altitudes prescribed for helicopters b y the FAA. As this exemption is for a sUAS that is a helicopter and th e exemption requests authorit y to operate 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, except for the limited conditi ons stated in the Manual, the UAS will never operate at higher than 400 AGL. Itwill however be operated in a restricted area with securit y perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safet y 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 propert y owner or local officials. Because of the advance notice to the property owner and1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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participants in the filming activity , all affected individuals will be aware of the planned flight operations as set forth in Section K of the Manual. Compared to flight operations with aircraft or January 6 th , 2016 Page Nine rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, an y risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL in the mov ie industry . In addition, the low

- altitude operations of the sUAS will ensur e separation between these s UAS operations and the operations 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 b y reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safet y will be achieved by the operator, pursuant to the Manual and Safet y Check list, confirming the altitude of the launch site s hown 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 cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery

powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS 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 predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within th e scope of prior exemptions. See Exemption 10673 (allowing L ockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightl y controlled area where onl y people 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 ty pe of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally , limiting sUAS flights to 10 minutes would greatl y reduce the utility for which the1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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exemption will be granted. Applicant believes that an equivalent level of safety can be achieved b y limiting flights to January 6 th , 2016 Page Ten 30 minut es or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from an yw here in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. **14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft 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 aircraft unless the airworthiness certificate required b y 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 weighs no more than 55 lbs and is operated w ithout an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by

keeping these documents at the ground control point wher e the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789 , 9789A, 9797, 9797A, 9816A, and 10700. **14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections** These regulations 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 prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircr aft in compliance with Part 43.1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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Given that these section and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by January 6 th , 2016 Page Eleven the operator pursuant to the flight manual and operating handbook as referenced in the Manual.(See Sections Land Q) An equivalent level of safet y will be achieved because these small UASs are very

limited in size and will carry a small payload and operate o nly in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prio r to initiating flight, perform required maintenance, and keep a log of an y m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition to provide the equiv alent level of safet y. **36 C.F.R. 1.5 (a) 1,2 and 3; (b) and; (c) : National Park Closures and Public Use Limits**  This regulation requires specifications for parks and national parks regarding visiting hours and public use limits. As we are only operating during day

time hours, as required b y section 333 of the reform act, we will limit visiting hours to onl y when it is safe and advised b y park rangers when they

deem it is and when they deem it is ok to operate within the park limits

Pursuant to 14 C.F.R . Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.1 13( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) ; 36 C.F.R 1.5 to operate commerciall y a small unmanned vehicle (55lbs or les s) in photograph y and television operations. Approval of exemptions allowing commercial operations of sUASs in the aerial photograph y industry

will e nhance safet y b y reducing risk. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the park and beach and not flown. The sUAS will carry no passengers o r crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safet y supp orting the grant of the1299 Pennsylvania Avenue, NW, Suite 700, Washington, DC 20004

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exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, January 6 th , 2016 Page Twelve close to the ground, and in a sterile environment and, and are very safe when operating in close proximity to the ground and people. **Privacy** All flights will occur over private or controlled access property with the property owner’s prior consent and knowl edge. Filming will be of peo ple who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. Set forth below are pictures of aerial filming conducted in both day and night environment, as flown today

in highl y populated and/or urban areas . The grant of this exemption request will provide improved safet y in both day and night operations. Satisfaction of the criteria provided in Section333 of the Reform Act of 2012

— size, weight, speed, operating capabili ties, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in the tel evision and photography industry pursuant to the Manual appended hereto.
I am a Sinclair Community College student studying unmanned aerial s ys tems with First Responder applications. Over the Fall 2015 semester, I completed the Laws and Regulations class for Unmanned Aerial Sy stems, and we filled out a 333 as the final paper. Sincerel y, Samuel W. Bry an