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US Department of Transportation Federal Aviation Administration 800 Independence Ave S.W. Washington, DC 20591 Dear Sir or Madam: SoundNStyle Inc. dba The Naples Studio / SoundNStyle Inc. dba First Class Aerials (“SoundNStyle) is submitting this petition on its own behalf, without legal counsel or consultation, in accordance with the terms set forth in Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 C.F.R. Part 11. SoundNStyle requests an exemption from the Federal Aviation Regulations (“FARs”) described below as they pertain to the operation of small Unmanned Aerial Systems (“UAS”). SoundNStyle is seeking said exemptions to commercially operate its small UAS within the National Airspace System (NAS) for the purpose of providing aerial videography and photography services. All SoundNStyle flight operations will be performed by a two
- person flight team and will be conducted in accordance with Section 333 of the Reform Act as set forth by the Federal Aviation Administration (“FAA”). Pursuant to 14 C.F.R. § 11.81(f), SoundNStyle is providing the following summary for publication in the Federal Register to be included at the discretion of the FAA: Petitioner: SoundNStyle Inc. Seeking Exemptions from Sections of 14 C.F.R: 14 C.F.R. Part 21, 14 C.F.R. § 45.23(b), 14 C.F.R. § 61.113(a) and (b), 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.109(a), 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) and (b), 14 C.F.R. § 91.215, 14 C.F.R. § 91.401 through 91.417, 14 C.F.R. § 91.7(a) and (b). Description of Relief Sought: SoundNStyle is requesting an exemption from sections of Title 14 of the Code of Federal Regulations to operate small (55 lbs. gross weight or less) unmanned aircraft systems under the control of licensed private pilots. Our petition is very similar in scope to the exemption granted to Astraeus Aerial under Exe mption No. 11062 ( Regulatory Docket No. FAA
-2014

-0352) and the associated Summary Grants (Regulatory Docket Nos. FAA

-2014

-0353, FAA
- 2014

-0354, FAA

-2014

-0356, FAA

2014

-0357 and FAA

-2014

-0358). Where applicable, SoundNStyle will adhere to the terms set forth in the Astraeus exemption. When applicable, training, maintenance and operations procedures will be modified/updated to comply wi th future regulations set forth by the FAA as UAS law is implemented

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The petitioner contact information is: SoundNStyle Inc The Naples Studio / First Class Aerials 501 Goodlette Rd N Suite B306 Naples, FL 34102 Phone: 239.430.2200 Email: drew@thenaplesstudio.com SoundNStyle is requesting exemptions from the following regulations:

 14 C.F.R. Part 21  14 C.F.R. § 45.23(b)  14 C.F.R. § 61.113(a) and (b) and 14 C.F.R. § 61.133(a)  14 C.F.R. § 91.109(a)  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) and (b)  14 C.F.R. § 91.215  14 C.F.R. § 91.401 through 91.417  14 C.F.R. § 91.7(a) and (b)
**GENERAL RESTRICTIONS AND ASSURANCES**  Using FAA Notice on National Policy N 8900.227, “Unmanned Aircraft Systems (UAS) Operational Approval” and Exemption No. 11062 as guidance, SoundNStyle will document and implement policies and training to ensure compliance with N 8900.227 Section 14 “Operational Requirements for UAS” and including the following restrictions:

(a.) All flight operations will be performed by a minimum of two (2) individuals: a Pilot in Command (PIC) and a Visual Observer (VO). (b.) PIC will conduct a pre

-flight briefing with VO and client or their designee to review flight profile, safety considerations and emergency procedures. (c.) PIC will perform a pre

-flight inspection of the UAS that includes: the communications link between the UA and ground control station, remaining battery charge, condition of airframe, propellers and wiring. (d.) During flight, PIC and VO will maintain direct communications and terminate flight operations if they are no longer able to- 3

- communicate with each other. (e.) Unmanned Aircraft (UA) shall not exceed 55 pounds gross vehicle weight (including any attached cameras, gimbals or other equipment). (f.) All flight operations will take place in Class G airspace no further than 3⁄4 nm from the PIC, below 400 feet AGL and at airspeeds less than 25 kts. (g.) All flight operations will take place under VFR conditions within visual line of sight (VLOS) of the PIC. No flight operations will take place at night. (h.) Flight operations will not be conducted over densely populated areas, heavily trafficked roads, at an air show or other environment that may include other low

- flying aircraft

. (i.) No flight operations will be conducted over an open -air assembly of people unless a comprehensive safety plan can be implemented to mitigate risk of injury to individuals or damage to property. (j.) Flight operations will be terminated when the UA battery reaches a remaining charge of 25 %. Additional information regarding General Flight Operations, PIC and VO qualifications may be found in Appendix A: SoundNStyle Equipment and Flight Operations Overview
**BENEFIT TO THE PUBLIC**  The requested exemptions will allow SoundNStyle to operate its UASs to provide commercial photography and videography services to its clients. In addition to advancing the “safe and expedient integration of UAS into the NAS” as mandated by the FAA Modernization and Refo rm Act of 2012, Public Law 112

-95 (P.L. 112

- 95), granting the requested exemption is in the public interest as: 1. A UAS generates less pollution from exhaust, has a lower noise signature and requires a substantially smaller to footprint from which to operate, making it more cost
-effective and environmentally friendly than full size, manned fixed

-wing aircraft and helicopters. 2. A UAS uses either an electric power source or a significantly smaller amount of flammable fuel than a manned aircraft, making it a safer platform than its manned counterparts. The UAS described herein are also more maneuverable and provide a greater safety margin at the speeds and altitudes required for aerial cinematography than full size- 4
- fixed

- or rotary
-wing aircraft. 3. When prope rly operated within the regulations set forth by the FAA, a UAS can be less disruptive to the NAS than its full

-sized counterparts because it does not require airports/runways, fueling apparatus or other infrastructure required by manned aircraft. Thank you for time and consideration of this petition. Please contact us if you require any additional information to process this request. Sincerely,

Drew Townsend, Owner and Pilot SoundNStyle Inc dba The Naples Studio SoundNStyle Inc dba First Class Aerial s

Attachments: Appendix A: SoundNStyle Equipment and Flight Operations Overview- 5
- **APPENDIX A: SOUNDNSTYLE EQUIPMENT AND FLIGHT OPERATIONS OVERVIEW**  **SoundNStyle Unmanned Aircraft Systems (UAS)** The SoundNStyle fleet includes a variety of small, Unmanned Aircraft (“UA”) that are built by experienced manufacturers and maintained locally by an expert who has experience and training on UA’s. The various UA designs allow SoundNStyle to deploy the best equipment within each particular flight requirements to remain as least disruptive to the NAS and surrounding environment. The following small UAs and related components/equipment make up the SondNStyle fleet: **Octocopter –**  **DJI S1000+ Diagonal Wheelbase**  1045mm **Frame Arm Length** 386mm **Frame Arm Weight (Including**  **Motor, ESC, Propeller )** 325g **Center Frame Diameter** 337mm **Center Frame Weight (with Landing Gear Mounting Base,** 

**Servos)** 1520g **Landing Gear Size** 460mm(Length)×511mm(Width)×305mm(Height) **Motor Stator Size**  41×14mm **KV** 400rpm/V **Max Power**  500W **Weight(with Cooling Fan)** 158g **ESC Working Current**  40A **Working Voltage** 6S LiPo **Signal Frequency** 30Hz ~ 450Hz **Drive PWM Frequency** 8KHz **Weight(with Radiators)** 35g **Foldable Propeller (1552/1552R)**  **Material** High strength performance engineered plastics- 6

- **Size** 15×5.2inch **Weight** 13g **Flight Parameters Takeoff Weight**  6.0Kg ~ 11.0Kg **Total Weight** 4.4Kg **Power Battery** LiPo (6S,10000mAh~20000mAh,15C(Min)) **Max Power Consumption** 4000W **Hover Power Consumption** 1500W (@9.5Kg Takeoff Weight) **Hover Time** 15min (@15000mAh & 9.5Kg Takeoff Weight) **Working Environment Temperature**  - 10 °C ~ +40 °C **SoundNStyle Flight Team Memebers** The SoundNStyle flight team will including the following individuals for ALL events: 1. A Pilot in Command (PIC), whose primary responsibility will be the safe operation of the UAS in accordance with the FARs. 2. A Visual Observer (VO), who will be responsible for ensuring that the UAS is being operated within the restrictions set forth in the FARs and to provide a second pair of eyes to mitigate any hazards to safe operations. The VO will receive orientation on the FAR and training on the responsibilities of an observer such as, but not limited to, flight team communications, properly monitoring the airspace and identifying hazards. 3. (Optional

– if required and on a project

- by

- project basis) A Camera Operator, (CO) who will operate any still or video camera included in the UAS. The CO is not considered a part of the flight team, but will be used when a project requires a moving camera instead of one that it locked in a fixed position, or if terrain, proximity to non

-Class G airspace or other environmental factors make the addition of a third team member prudent. **SoundNStyle Flight Team Qualifications and Responsibilities**  Each member of the SoundNStyle team will meet a minimum set of qualifications, including training and licenses to ensure team and public safety is kept at the highest priority. During operations, flight team members will be responsible fo r specific tasks to divide the workload and further enhance safety. Pilot in Command (PIC) The PIC holds the proper licenses/certifications to conduct the flight and has final authority over all operations (regardless if UA is in the air at the time) and- 7
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responsibility for safely operating the UA. A PIC will be designated prior to flight operations and only one person will be the designated PIC at any time. At minimum, the PIC will possess the following:

1. FAA Private Pilot License and required medical certifications 2. The PIC will be qualified to operate the UA by possessing a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type. 3. Successful completion of SoundNStyle training on the proper pre-flight inspection of UAs. The PIC’s duties include:

1. Evaluating the environment for hazards 2. Performing pre

-flight checks and briefings 3. Safely operating the UA within the FARs 4. Coordinating with the VO to evaluate the operating area for safety 5. Terminating flight operations and landing the UA as soon as practical and safe to do so if unsafe conditions arise. Visual Observer (VO) The VO is responsible for overseeing the safety aspects of UAS operations on each project and enforcing all FAA regulations set forth in the Reform Act. At minimum, the VO will demonstrate knowledge of the requirements defined in 14 C.F.R. including: operations near other aircraft, right

-of

-way and basic VFR, plus the proper use of pilot/air t raffic control phraseology. VOs who are not licensed private pilots will also complete a comprehensive SoundNStyle training program to ensure that:

The VO fully understands the FARs as they relate to the safe operation ofa UAS and the importance of complying with them, The VO is familiar with crew resource management and clearly understands his/her role as it relates to the PIC, The VO is able to accurately read and interpret aeronautical charts, NOTAMs, COAs, weather forecasts and any other informat ion required to ensure safe operations, The VO is able to effectively communicate and coordinate with the PIC to ensure a safe operating environment The VO has the opportunity to gain hands

-on experience with a PIC, before participating on a paid project, to validate knowledge and address any questions or concerns in an environment that is dedicated solely to knowledge transfer between SoundNStyle crew.- 8

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**SoundNStyle Flight**  **Operations** Pre
-flight The PIC and VO will conduct a pre-flight briefing that includes: Review aeronautical charts to o ensure that planned operating area is compliant with FARs o identify known hazards to navigation- 9

- o determine safe divert areas (if applicable) Review weath er forecasts Review all Notice to Airmen (NOTAM) that may be active in the operating area When required, obtain a Certificate of Waiver or Authorization (COA) from the regional ATO When required, submit a notice of planned operations to the appropriate Flight Standards District Office (FSDO) a N OTAM between 72 and 48 hours prior to commencing operations Perform a pre

-flight maintenance check to ensure that the UAS is functioning according to manufacturer specifications including the communications link between the UA and ground control station, remaining battery charge, condition of airframe, propellers and wiring. Inspect the UA to comply with maximum weight limitations of 55 lbs. gross weight Display a sign or other notice indicating that UAS operations are in progress in the area and identifying SoundNStyle as the owner/operator of the UAS. The ground control station is a portable unit that is worn by the PIC to ensure freedom of movement should repositioning be required to maintain proper visual line of sight. As such, the notification sign will be placed within 10 feet of the PIC’s initial position and moved, as required, and never to exceed a distance of 20 feet from the PIC. Additionally, flight operations will primarily be conducted within a closed set environment or in an area where only authorized and consenting individuals are allowed. In
-flight The PIC will operate the UAS in accordance with the FARs and SoundNStyle preflight briefing described above to maintain public safety. During flight operations, the PIC will: Navigate the UAS within the operational area Monitor altitude and airspeed Maintain visual line of sight (VLOS) with the UA Monitor battery charge/remaining flying time The VO will: Monitor UAS operations to cross

-check PIC and ensure that the UA stays within VLOS and within the required altitude and airspeed limitations, Monitor the airspace to ensure that aircraft, birds or other airborne hazards remain out of the operating area, Monitor the general operating area to ensure that the UA maintains proper separation from hazards, restricted or unauthorized airspace and that no ground hazards, such as unauthorized persons or vehicle enter, the- 10

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operating area, Monitor weather conditions to ensure that wind, cloud ceiling or other factors do not exceed safe operating parameters Immediately instruct the PIC to terminate flight operations and assist the PIC to safely land the UA if any unsafe conditions arise.