September 11, 2015 U. S. Department

of Transportation Docket Management System 1200 New Jersey Ave., SE Washington,
DC 20590 RE: Petition of Josh Thompson Media LLC for Exemption Pursuant to Section 333 of the FAA Reform Act Petitioner's Name and Address: Josh Thompson Media LLC Owner: Josh Thompson 2669 Trophy Court Abrams, WI 54101 920-430-0852 josh@joshthompsonmedia.com To whom
it mayconcern: Pursuant to Section 333 of the FAA Modernization
and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Josh Thompson Media 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") toallow commercial operation of its sUASs, so long assuch operations areconducted within and under the conditions outlined herein oras maybe established
by the FAA as required by Section 333.1 As described more fully 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
and 3) controlled. The proposed exemption,

if granted, would allow Josh Thompson Media LLC to conduct commercial operations
of sUASs meeting or exceeding

all of the operational and safety requirements Congress has setforth in Section 333. Josh Thompson Media LLC is a media/technology companyowned and operated
by Josh Thompson. The purposeof Josh Thompson Media LLC is to develop commerce

in Northeast Wisconsin. Mr. Thompson has over10 yearsin Remote Controlled ("RC") aircraft experience

in both fixed wing and rotary aircraft. This experience includes development, building, testing and flying
a variety of RC aircraft.

# Josh Thompson Media LLC plans to use the capabilities
of sUASs to offer
a multitude
of services, including:

- Event Photography/Videography - Real Estate Photography and presentation -Aerial filmmaking and photography - Construction site inspections and monitoring Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides

a mechanism for seeking expedited FAA authorization

of safe civil Unmanned Aircraft Systems (UAS) operations

in the National Airspace System ("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 section 332(b)(1)
of this Act or the guidance required 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 requirements

to permit FAA approval of commercial UAS operations. The name and address of the applicant are: Name: Josh Thompson Media LLC Owner: Josh Thompson Address: 2669 Trophy Court Phone: Email: Abrams, WI 54101 920-430-0852 josh@joshthompsonmedia.com 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) 14 C.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. 91.121Page

3 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) sUASs are oftentimes seen as superior to helicopters due to the lesser cost of equipment, the reduction
of personnel needed to operate equipment, reduced noise levels and zero emissions 2into the environment.

In addition to providing cost savings and having little tono impact onthe environment, sUASs provide enhanced safety. These factors arebeneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests that the FAA grantthe requested exemption without delay. Petitioner

is requesting
an exemption

toenable Josh Thompson Media LLC to operate

aDJI Phantom

3 {http://www.dji.com/product/phantom-3/feature)

sUAS that is latest version of the Phantom Line, equipped with a 3 axis camera gimbal, which usesa High-Def video camerathat can capture upto4K {4096x2160p) video and 12M pixel photos. This sUAS has abuilt-in capability
tolimit 1) the height
it flies above the ground and 2) the radius of the distance

it flies from the operator. The OJI Phantom

3 also has the failsafe function of the autopilot system, which means,when the communication between the Main Controller and the transmitter

is disconnected, the outputsof all command sticks from controller will gotothe center position.

If the GPS signal
is good enough, the systemwill automatically trigger Return toHome and will land safely. Please refer to spec attachment, the DJI Phantom

3 Specs, for the performance limitations and flight operations. Aircraft weight

is 1280 gramswith battery, which

is the total gross weight. A pre-flight inspection will be performed
by the PIC in accordance with the factory instruction manual,
aswell asredundant checks to include the Internal Measurement Unit {IMU) tomake surethat the compass, gyroand acceleration values arewithin specs, positive GPS locks are secure, battery health
in each individual LiPo cells are balanced, and radio signals arelocked in. The sUAS will be maintained

in accordance with the manufacturer's instruction manual and only manufacturer's authorized replacement partswill be used. FCC Information The OJI Phantom

3 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation

is subject tothe following two conditions:
{1) This device maynotcauseharmful interference, and {2) this device must accept anyinterference received, including interference that maycauseundesired operation. The DJI Phantom

3 radio transmitter used for controlling the sUAS
is wireless technology which has been tested and found tobe compliant with the applicable regulations governing

aradio transmitter

in the 2.400GHz
to 2.4835GHz frequency range. Antenna Separation Distance When operating the DJI Phantom

3 transmitter, the PIC will maintain

a separation distance of at least
5 embetween his body {excluding fingers, hands, wrists, ankles and feet) and the antenna tomeetRF exposure safety requirements

asdetermined

by FCC regulations. Pilot in Command and Observer Qualifications and Duties 3The PIC will maintain
atleast
a Light Sport Pilot Certificate and acurrent State issued drivers license, plus atleast
2 hours flying time and 3 takeoffs and landings within 30 days in the typeof UAS utilized

in operations. The PIC will have atleast 100 hours total time and atleast 30 hours flying Radio Controlled Model Aircraft, of which, 10 hours will be flying sUASs. The PIC is responsible for the safe and efficient operation
of the aircraft. Specific duties include all preflight preparation and inspection,

in flight operation, post flight requirements,
and all procedures including but not limited to: •Safe in flight operations •Risk evaluation •Current weather conditions for safe flight The Observer must have the visual acuity to observe the sUAS and be able to communicate clearly with the PIC. The Observers duties are: • Warning the PIC of any impending obstacles

in the flight path of the sUAS. • Warning the PIC of anydeviations

in the planned flight path of the sUAS. • Warning the PIC should anyunauthorized personnel appear
in the areaof the planned flight. The Observer will have the authority
toorder the PIC to terminate the flight should he feel the flight cannotbe conducted safely. General Operating Standards •Josh Thompson Media LLC will only operate its sUAS in line of sight of a pilot and/or observer and will operate
atsites that area

1 SUfficient distance

1 from populated areas.Such operations will insure that the sUAS will

11 not create

ahazard tousersof the national airspace systemorthe public.

11 •Before an operation
of asUAS within SNM of an airport with
acontrol tower, the control towerwill be called to gain permission
to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will notbe operated
atan altitude of over200 feet AGL. Weather minimums will be 3 miles visibility and a1000 foot ceiling. •Before an operation
of asUAS within SNM of anon-tower controlled, airport operatorswill be notified and the PIC will give the right of waytoavoid flying in the proximity
of full-scale aircraft. At notime will the sUAS be operated within the final approach courseand the takeoff courseof any runway.The sUAV will notbe operated
atanaltitude of over200 feet AGL. Weather minimums will be 3 miles visibility and a1000 foot ceiling. •Maximum flight time for each operational flight will be 18 minutes. 4• Flights will be terminated

at 30% battery powerreserveshould that occur prior tothe 18minute limit. •The sUAV will be programmed

sothat it will notbe operated
atanaltitude of nomorethan 200 feet AGL, and notmorethan 200 feet above anelevated platform from which filming is planned. •Minimum crewfor each operation will consist of the sUAS Pilot, and Visual Observer. •The sUAV operated
by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals). •The sUAS will operate
at speeds of nomorethan 25 knots, can hover, and can simultaneously move vertically and horizontally. •Given the small size of the sUAV and the restricted sterile environment within which they will operate, oursUAV operations adhere tothe Reform Act's safety requirements. The sUAS, powered by batteries,

is smaller, lighter and moremaneuverable than larger aircraft running oncombustible fuel. The sUAS operates
atlower altitudes with no people onboard and will thereby reduce current risk levels, enhance safety and diminish the likelihood
of death or serious bodily injury. With
asmall payload and maximum flight time of only 20 minutes, this offers little ornorisk to national security. Low level oblique photos and video from several angles arefar moreeffective than ground based imagery for displaying the characteristics

of large, complex properties with several buildings and large trees. The benefits of reduced costand improved quality of presentation from the sUAS overmanned aircraft will be valuable
toand benefit many buyers and sellers of real property, farmers and ranchers, and local city officials tomonitor ourlocal water supply. Additionally,
we request that webe allowed touseour systemtobenefit first responders nearby who might require assistance, including fire fighters, police, sheriff, etc.,all while remaining subject toall limitations cited below: (a) No flight will be made with
aGross weight exceeding
55 pounds; (b) All operations must occurin FAA Class G airspace
atnomorethan 200ft AGL, atan airspeed of nomorethan 25 knots and nofurther than 1600 ft, or0.263 NM from the PIC; (c) All operations must utilize

avisual observer (VO). The VO and PIC mustbe able to communicate

by voice atall times during

a flight operation; (d) Operations will be restricted
to flights over private propertywith the permission

of the property owner;

5(e) All required permits will be obtained from stateand local government prior to operation; (f) Josh Thompson Media LLC will notbe operated over densely populated areas; (g) Josh Thompson Media LLC will notbe operating over any open-air assembly
of people; (h) Josh Thompson Media LLC will notbe operating over heavily trafficked roads; (i) Josh Thompson Media LLC will notbe operating
at night. EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Josh Thompson Media LLC requests
an exemption from the following regulations

aswell as any additional regulations that may technically apply tothe operation
of the sUAV System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of anairworthiness certificate. While the FAA continues
towork to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate
be issued for the DJI Phantom

3 under either orboth of the following provisions: 21.191 Experimental certificates. Experimental certificates areissued for the following purposes: (a) Research and development. Testing newaircraft design concepts, newaircraft equipment, newaircraft installations, newaircraft operating techniques,

ornewusesfor aircraft. (b) Showing compliance with regulations. Conducting flight testsand other operations
toshow compliance with the airworthiness regulations including flights toshow compliance for issuance of typeand supplemental type certificates, flights to substantiate major design changes, and flights toshow compliance with the function and reliability requirements

of the regulations. Since the experimental certificate canbe used for commercial purposessuch asmarket surveys,sales demonstrations,
and customer crew training, wewould expect that an experimental certificate would permit ourcommercial purpose
aswell. The aircraft will not carry personsor property,will not carry fuel, and will only fly under strict operational requirements. Combined with the UAS

1 s light weight, being constructed primarily
of carbon fiber and plastic, we proposethat the UAS will be atleast assafe, if not safer, than
a conventionally certificated aircraft performing the 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 anairworthiness 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 marks. These regulations provide that each aircraft must display

11 N11 and the aircraft

1 s registration number

in letters atleast
3 inches high. Additionally, the aircraft must display the word 11 EXPERIMENTAL

11 in letters atleast
2 inches high nearthe entrance tothe cabin, cockpit, or pilot station. The sUAS does nothave anentrance

in which the word

11 EXPERIMENTAL

11 canbe placed, 6and maynothave
a registration number assigned toit by the FAA. We proposeto achieve an equivalent level of safety by including the word "EXPERIMENTAL"

in the placard onthe topof the aircraft,
asshown above, where the PIC (Pilot In Control), VO (Visual Observer) and others
in the vicinity of the aircraft while
it is preparing for launch will be able toseethe designation. Additionally,
wefeel that the permanent placard discussed

in the previous paragraph will provide the aircraft's registration information

atthe ground station. Finally, wewill display atthe ground station

a high contrast flag orbanner that contains the words "Unmanned Aircraft Ground Station"

in letters

3 inches high or greater. Since the aircraft will operatewithin 0.263 NM of the ground station, the banner should be visible to anyonethat observes the aircraft and chooses to investigate
its point of origin. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no personthat holds
aPrivate Pilot certificate mayactas pilot in Command
of anaircraft for compensation

orhire. Subparagraph

(b) allows

a private pilot toact as pilot in command
of anaircraft
in connection with anybusiness or employment

if: (1) The flight is only incidental
tothat business or employment; and {2) The aircraft does not carry passengers or property for compensation

orhire. Our proposed operations require that the PIC must hold at least
aPrivate Pilot Certificate with
aClass Ill Medical issued by the FAA and since the aircraft cannot carry passengers
or property, wefeel wemeetthe intent of 61.113 Subparagraph

(b) even though the intent of this application

is to conduct

abusiness. 14 CFR 91.7 Prohibits the Operation
of anaircraft without anairworthiness 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 anaircraft unless

a current, approved flight manual

is in the aircraft. We assumethat the intent of this requirement

is to ensurethat flight manual information

is available
tothe aircrew while operating the aircraft. We request an exemption
tothis requirement since the aircraft

is not only toosmall to carry documentation, the documentation would notbe available
tothe crew during flight operations.
To obtain an equivalent level of safety and meetthe intent of 91.9, we proposethat a current, approved sUAS Flight Manual mustbe available
tothe crewatthe ground station anytime the aircraft

is in, or preparing for, flight, and ready for presentation
for any governing official upon request. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate

acivil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. Although the DJI Phantom

3 is capable of duel/linked controls, Josh Thompson Media LLC will be operating with
a single remote controller. 91.119 Minimum safe altitudes:

7General. The regulation states that over sparsely populated areasthe aircraft cannotbe operated closer than 500 feet to any person, vessel, vehicle, orstructure. Since the typical mission of the sUAS would be photography

or surveyof persons, vessels, vehicles orstructures

it would be necessary
to operate closer than 500 feet tothe items listed. Operations will only be flown over propertyor personswhere permission has been obtained and careful pre-planned flight path has been performed. The aircraft will be operated
atalow altitude allowing,

if a powerunit fails, an emergency landing without undue hazard to personsor property onthe surface. Therefore we maintain that due tothe small size of the UAS, the hazard to persons,vehicles and structures

is minimal compared
to manned aircraft, which should be considered

in granting the exemption. CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference
toanaltimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 200 feet AGL and will notneed to maintain cruising altitudes

in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point
is transmitted
via radio from the sUAS on-board computer
tothe display screenheld 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 enough fuel to fly tothe 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 energyreserveasa safety buffer for delays to landing. The sUAV
is battery operated and the maximum duration of flight from
a single battery charge

is 18 minutes with a20% reserve.Since the aircraft will never fly morethan 0.263 NM from the point of intended landing,

afull battery charge atlaunch will ensurethat wemeetthe reserve energy requirement

of this paragraph. We request an exemption
tothe word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR 91.203(a)

& (b) Civil aircraft: Certifications required. The regulation provides that anairworthiness certificate, with the registration number assigned tothe aircraft and
a registration certificate mustbe aboard the aircraft. Additionally, subparagraph

(b) provides that the airworthiness certificate
be "displayed

atthe cabin or cockpit entrance
sothat it is legible to passengers
orcrew." At amaximum gross weight of 6.47 pounds, the sUAS
is toosmall to carry documentation, does nothave an entrance, and is not capable of carrying passengers

orcrew.To obtain an equivalent level of safety and meetthe intent of 91.203, we proposethat documents deemed appropriate for this aircraft by the FAA will be with the crewatthe ground control station and available for inspection upon request.

In order to identify the aircraft, we proposethat the information found onairworthiness and registration certificates

be permanently affixed tothe 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 8require that the aircraft be "approved for returntoservice by a personauthorized under 43.7" after maintenance and inspection.

It is ourintention that the PIC perform maintenance and inspection
of the aircraft and "be authorized
to approvethe aircraft for returnto service." The PIC will ensurethat the aircraft

is in an airworthy condition prior to every flight and in addition conduct detailed inspections after everytwohours 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

ortheir designated repair facility. The PIC will document work performed

in accordance with 91.417. We feel that due tothe size, construction, and simplicity of the aircraft, the PIC canensurean equivalent level of safety. Safety and Benefits of the UAS Josh Thompson Media LLC will be using the UAS in a variety of applications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefits overthe useof full-sized manned aircraft for aerial photography and Videography, film and still photography, real estate marketing, and water supply monitoring. Replacing significantly larger manned aircraft carrying crewand flammable fuel with small UAS carrying no passengers
orcrewcreates

amuch greater margin of safety for the pilots and crew. By granting Josh Thompson Media LLC's 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. Josh Thompson Media LLC is committed
to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving
asaresourcefor future UAS research operations. Thus, the FAA has good causeto grantthis Petition. Conclusion As pointed outin this application, the DJI Phantom

3 which our companywould use,under authorization

by the US DOT-FAA,

is asmall, light-weight device operated within the line of sight ofthe Pilot-in-Command (PIC), less than 200 feet above the ground and outside

5 miles from any airport, heliport, seaplane base, spaceport,
orother location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within

a radius of this distance. The DJI Phantom

3 has been proven capable for controlled flight.

It is aUAS offered for general sale onthe market around the world and have often been used asModel Aircraft

in the USA. We arecertain that the studies conducted until now by the FAA, about Section 332, Public Law 112- 95, 2014, have already provided youwith the assurances
onthe airworthiness

of sUAS such as ours. For the foregoing reasons,the exemptions requested herein should be granted and Josh Thompson Media LLC should be permitted
to conduct small UAS operations

in accordance with its manuals and all other operating parameters deemed necessaryand appropriate

by the FAA. 9The submission
of this application and its contents

is the best demonstration that indeed

it is possible to pursuethe authorization processsothat someSUAs maybe used for legitimate commercial activities and under reasonably safe conditions. 10