Floyd Fishel and Cooper Dunn OP Media, LLC 2221 Peachtree RD NE Ste D Box 412 Atlanta, GA 30309 404-457-6694 info@opmedia.net

Petition for Exemption Federal Aviation Administration

Unmanned Aircraft System (DJI Inspire 1 Drone) use in NAS for compensation

Objective : Petitioners, Floyd Fishel and Cooper Dunn, hereby petitions the Federal Aviation Administration (FAA) on the respective behalf of their own and , OP Media, LLC, for exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 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); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This exemption, if approved, grants operation of unmanned aircraft systems (UAS) for the purpose of commercial/industrial use and scripted, closed-set filming for the motion picture and television industry.

The petitioners posit the following terms and conditions for exemption status herein requested:

Areas of for hire use:

Commercial Packages :
OP Media LLC seeks to enter the market and provide aerial video and photo content for corporate clients (golf courses, residential/commercial real estate, large corporations, and state agencies) that wish to leverage the benefits this dynamic content to promote and deliver impactful media

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Motion Picture/Film:

In effort to extend and offer creative options to the greater public at large, Cooper Dunn and Floyd Fishel will leverage Cooper’s extensive past experience as a director of photography to bring new and innovative imagery while utilizing the DJI Inspire 1 platform. As a result, our company will empower our clients and continue to drive innovation in the film community.

Industrial Purposes:

OP Media LLC has the skill set to provide industrial services for construction companies, agriculture, and private/public municipalities that wish to use aerial footage to assess(roofs, pipeline mechanisms, plant operations, crop growth, etc.) the integrity and progress of development sites

.Description of Unmanned Aircraft System

The UAS refers to the DJI Inspire 1 Quadcopter, which contains four rotors as well as four motors configured as a quadcopter. The DJI Inspire 1 is a modern quadcopter controlled by a piloting team that utilizes integrated real-time flight data through an FPV displayed through a mobile device. The flight team is able to take advantage of a dual remote control system to provide a customizable team approach to flying. The DJI Inspire 1 employs a GPS based alignment system with an accuracy of 1.6 inches vertical and 8.2 inches horizontal. The copter can reach speeds approaching 35 mph in GPS mode and upwards of 45mph in manual “attitude mode”. The Inspire 1 can ascend at speeds reaching 10mph and descend at speeds reaching 8mph. OP Media LLC will operate with a maximum height range of 500ft in accordance with recommended FAA guidelines for UAS. The DJI Inspire 1 can safely operate in temperatures 32-104 farenheight. With a battery the quadcopter weighs 6.5 lbs with a flight time of up to 18 minutes depending on wind conditions and maneuvers. DJI uses custom motors model DJI 3510. When the Inspire is not able to fly in GPS mode, it utilizes an optical sensor that operates best with an altitude range of 2” to 198” and light conditions greater than 15 lux.

Widespread use of the DJI Phantom series, partnered with the world wide release of the DJI Inspire 1, illustrates a stable and safe entrance into the Unmanned Aircraft market. The referred to UAS falls within current FAA recommendations: weighs <45 lbs., will not exceed an altitude of 500 feet AGL, per UAS GPS system measurements, will be within the Command Pilot’s line of sight, will have a remote safety observer in perpetual communication with the PIC within 5 feet of each other, will not fly more than 40 MPH, will be limited to dawn to dusk flights, will always use Visual Flight Rules within visual line of sight, will never use first-person view by the PIC, while the PIC will have discretionary use of human vision unaided by any device aside from corrective lenses per current state issued drivers license specification, with 72 hours advance notice to the local FSDO of flight operations, the PIC will have >200 hours logged flight experience in equivalent UAS type or model, including a minimum of 10 takeoffs and landings within 30 days, with a robust holistic aircraft inspection by the PIC before takeoff.

The DJI Inspire 1 Satisfies The Statutory Criteria For Approval Under Section 333.
The DJI Inspire 1 is defined as an UAS that qualifies for expedited approval under Section 333 for the commercial media purposes proposed by OP Media LLC . Each of the statutory criteria and other potentially relevant factors are satisfied:

1. Section 333(b)(1) Criteria

a. Size
The Inspire 1 is 22.9 inches in diagonal length and overall 17.2in x 17.9in x 11.9in. Propellers are just under 1ft in length. Carbon fiber construction provides a balance between rigidity and optimal weight for steady flight. The DJI Inspire 1 easily meets the recommended suggested size for safe UAS use (See Exhibit 4).b. Weight

The Inspire 1 weighs 6.5 lbs. with battery and camera in place.
c. Speed The Inspire 1 is often flown at speeds of 25 mph or less. However, in motion picture situations where designated flying areas will be restricted to the public and professionals are taking part in the scene, speeds could reach upwards of 40 mph for a tracking shot. Inspire 1 has a maximum speed of approximately 45 mph.
d. Operational Capability
The Inspire 1 is capable of operating in the intuitive GPS mode that allows programmable flight patterns and Attitude GPS assisted mode that allow more open manual control by a skilled pilot with higher top end speeds for ascent, descent, and horizontal flight patterns(see exhibit 4).
The transmitters operate in the 5ghz band between controllers and 2.4ghz band between controller and aircraft.
The DJI Inspire 1 is capable of recording video in 4k at 24 and 30 frames per second as well as 1080p at 24, 30, and 60 frames per second while utilizing micro-sd cards for storage. The Inspire 1 is also suitable for recording still images in single or burst mode.
The integrated FPV system sets the unit apart by providing real time essential information updated to insure those in charge of flying are updated in real time areas that
e. Proximity to Airports/Populated Areas

For commercial purposes, the Inspire 1 will be flown over controlled areas (e.g., golf courses, construction sites, work facilities, and open fields) and away from airports (i.e., three nautical miles or more) or populated areas(1 nautical mile). For the most part, the Inspire 1 is flown at low altitudes of 250 feet or less. It is typically flown within a range of only 150 meters (i.e., 492 feet) from the operator.
f. Visual Line-of-Sight

Solution : We always employ a two person flight team to insure line of sight, coverage on the ground, and redundant skilled operators should one operator become physically unable to fly mid-flight.
g. Maintenance:
The PIC follows the manufacturer’s(see exhibit 1) UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life-limit requirements. Minimum operator manual requirements include:

a. Actuators / Servos b. Transmission (Single Rotor)c. Powerplant (Motors) d. Propellers e. Electronic Speed Controller f. Batteries g. Mechanical Dynamic Components (Single Rotor) h. Remote Command and Control i. Ground Control Station (if applicable) j. Any other components as determined by the operator
Applicable Statutes: Based on previous methods of operation and attention to safety, OP Media LLC satisfies the relevant statutory criteria and related factors for expedited approval pursuant to Section 333, including waiver of airworthiness certification under Section 44704. In addition, the DJI Inspire 1 meets the requirements and policies for exemptions, pursuant to Section 44701(f), from the FAA’s related airworthiness certification and related regulations (i.e., 14 C.F.R. parts 21, 27, and 14 C.F.R. §§ 45.23(b), 61.113(a)–(b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a)–(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)–(b), and 91.1501).

1. 14 C.F.R. Part 21: Airworthiness Certification
Part 21 establishes procedural requirements for certifications under Section 44704, including airworthiness certificates. Both Sections 333 and 44701(b) authorize the FAA to exempt aircraft from airworthiness certification under this Part. As shown above, the DJI Inspire 1 adheres to standards for exemption from Part 21 based on its size, weight, speed, operational capability, and proximity to airports/populated areas. See Section 333. Furthermore, the described use of the DJI Inspire 1 without an airworthiness certificate in the corporate and film/television operating areas identified above is much safer than conventional aircraft operating with an airworthiness certificate, and would provide multiple benefits to the public. In turn, OP Media LLC. requests an exemption from Part 21’s requirements for airworthiness certification.
2. 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft

Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. Since the DJI Inspire 1 would necessitate a certification under Part 27, as a rotorcraft, OP Media LLC. requests an exemption from Part 27’s airworthiness standards for the same reasons identified above.
3. 14 C.F.R. § 45.23(b): Marking Requirements
Section 45.23(b) states that on limited, restricted, or light-sport category aircraft, markings must identify the aircraft category and must be displayed “near each entrance to the cabin, cockpit, or pilot station.” Exemption from § 45.23(b) is suitable because the DJI Inspire 1 lacks an entrance to the cabin, cockpit, or pilot station, therefore the required marking can be displayed. OP Media LLC reserves the right to display any marking deemed worthy by the FAA, should it be necessary, to guide the organization of the UAS movement in lieu of location requirements of § 45.27(a) and thesize requirements of § 45.29(f). In turn , OP Media LLC requests an exemption to § 45.23(b)’s marking requirements.
4. 14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command
Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 61.113(b) grants an exception that allows a private pilot to command an aircraft, without passengers or property, in connection with business or employment if “[t]he flight is only incidental to that business or employment.” This exemption will provide access to media production contracts that are based solely on the ability to deliver aerial video content. By granting this exemption, OP Media LLC. will benefit the greater public by offering safe engaging aerial content that will benefit their business objectives. Since the content collected for clients is not incidental, OP Media LLC. requests an exemption to § 61.113(a)’s commercial limitation and/or § 61.113(b)(1)’s requirement that the flight be incidental to the business to benefit from the exception.
5. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness
Section 91.7(a) requires that a civil aircraft be in an airworthy condition to be operated. The DJI Inspire 1 has recently been released world wide after a successful launch of the DJI Phantom 2 series. In-depth survey of current news outlets and UAS forums have show the DJI system to be stable and reliable to operate within OP Media LLC productions. Aircraft airworthiness condition is aligned to: advanced GPS based piloting systems, comprehensive battery monitoring, manual flight logs maintained by PIC, and recommended manufacture maintenance schedules. Even more so, DJI constantly posts updates to firmware and promote public safety and conscientious operatingpractices through their DJI Pilot app and their website. Their operating instructions include a indepth preflight safety protocol for operation of each unit (See Exhibit 5). OP Media LLC. requests an exemption from this requirement

. 6. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft
Section 91.9(b)(2) does not allow a person to operate a civil aircraft “[f]or which an Airplane or Rotorcraft Flight Manual is not required by § 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 any combination thereof.” Due to the size, physical build, and load capacity, the DJI Inspire has no no ability to carry such a manual. Even more so, UAS have no pilot on board making an on-board manual unnecessary. In turn, the safety-related purposes of this manual(see exhibit 5) requirement will be adhered to with the flight manual stationed at ground control with open access by the pilot operating the DJI Inspire 1. In turn, OP Media LLC requests an exemption from § 91.9(b)(2)’s flight manual requirements, on the condition that the DJI Inspire 1 flight manual be available at the ground control point during each operation.
7. 14 C.F.R. § 91.103: Preflight Action
Section 91.103 requires a pilot in command to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. As no FAA-approved Flight Manual will be provided, OP Media LLC requests an exemption from § 91.103that would allow for the use of the DJI Inspire 1 operation manual, which includes a preflight checklist. See Exhibit 1

. 8. 14 C.F.R. § 91.109: Flight Instruction
Section 91.109(a) provides that “[n]o 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.” The DJI Inspire 1 is a UAS designed without fully functioning dual controls; instead, a mentoring pilot can be near by to insure proper technique an easily take over the remote control should the pilot need assistance. Furthermore, the manufacture recommended safety guidelines are the foundation of any flight(see exhibit 4). Such an approach insures public safety and provides structured support for developing pilots in command. In turn, OP Media LLC requests an exemption to § 91.109’s flight instruction requirements.
9. 14 C.F.R. § 91.119: Minimum Safe Altitudes
Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate,including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section § 91.119(d)(1) allows for a helicopter to operate at less than those minimum altitudes when it can be operated “without hazard to persons or property on the surface,” provided that “each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA.”
To provide the intended varied-scope services, the DJI Inspire 1 will be operated at 250ft altitude or less in most situations. In addition, to safely fly a UAS requires the pilot in command and the designated spotter be less than 500 feet away during operation. With widespread use of the DJI Inspire 1 and similar units, the safety performance will be similar to, if not better, operating within the specified regulatory requirements. By operating at lower altitudes within the line of sight between the flight team and UAS, the DJI Inspire 1 will not interfere with other aircraft that are subject to the minimum safe altitude regulations. An exemption from § 91.119’s minimum safe altitude regulations is warranted.
10. 14 C.F.R. § 91.121: Altimeter Settings
Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. The DJI Inspire 1 utilizes a GPS to determine its location. Its height is constantly monitored through the DJI Pilot mobile app system used by the pilot in command and spotter, thus insuring operation at safe altitudes. For these reasons, OP Media LLC requests an exemption to § 91.121’s altimeter requirements.
11. 14 C.F.R. § 91.151(b): Fuel Requirements for Flight in VFR Conditions
Section 91.151(b) prohibits a person from “begin[ning] a flight in a rotorcraft under VFR [(i.e., Visual Flight Rules)] 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, to fly after thatfor at least 20 minutes.” The DJI inspire 1 is battery powered and can fly at maximum for 22 minutes of flight time using extended batteries. Since the 18-22 minute flight window is ample time to safely capture planned and scripted shots by using carefully charged batteries to power the UAS, OP Media LLC. requests an exemption to § 91.151(b)’s fuel requirements because all of its flight times will be 22 minutes or less.
12. 14 C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration
Section 91.203 requires a civil aircraft to have “within it . . . [a]n appropriate and current airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” OP Media LLC. is seeking an exemption from the airworthiness certificate requirement and an exemption to this regulation. The DJI Inspire 1 is built to handle a specific load capacity to insure proper balance and camera movement, therefore it cannot carry a certification within the UAS. In extension, the DJI Inspire 1 lacks a cabin or cockpit entrance to display said certificate, and there are no passengers or crew that would benefit from such a display. In turn, OP Media LLC requests an exemption to § 91.203(a) & (b)’s requirements for carrying airworthiness certifications.
13. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b): Maintenance Inspections
These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections . . . have discrepancies repaired as prescribed in part 43 of this chapter”). OP Media LLC will need to be exempt from these regulations is needed because Part 43 and these sections apply only to aircraft that have been granted an airworthiness certificate, which the DJI Inspire 1 will not have. However, proper alignment of safe maintenance and inspection practices can be achieved using the recommended manufacturer maintenance requirements and careful oversight by experienced PIC and spotter(See Exhibit 1). OP Media LLC requests an exemption to the maintenance and inspection requirements contained in §§ 91.405, 91.407(a)(1), 91.409(a)(2), 91.417(a), and 91.417(b).
14. 14 C.F.R. § 91.1501: Continued Airworthiness
Section 91.1501(a) “requires operators to support the continued airworthiness of each airplane.” The DJI Inspire 1 will lack an airworthiness certificate, however an equivalent level of safety can be achieved when operated under the recommended FAA guidelines for UAS in addition to the conditions delineated above. In turn, OPMedia LLC requests an exemption from § 91.1501’s continued airworthiness requirements.
15. 14 C.F.R. Part 137: Agricultural Aircraft Operations
Part 137 provides requirements for the certification and operation of agricultural aircraft. A few of the requirements stipulate that the aircraft must be certificated and airworthy, see 14 C.F.R. § 137.19(d), and “equipped with a suitable and properly installed shoulder harness for use by each pilot,” id. § 137.31(b). Many areas of focus in Part 137 were designed for manned aircraft, therefore they shouldn’t be applicable to the unmanned DJI Inspire 1. An airworthiness certification is required tosatisfy the Part 137 requirements, yet OPMedia LLC’s DJI Inspire 1 won’t have one. As a result, OP Media LLC requests an exemption from the Part 137 airworthiness certification and operations requirements for agricultural aircraft

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Further Considerations:
Mandatory PIC inspection of UAS must occur prior to every flight to ensure safety. Should inspections reveal UAS has an operational malady, then the aircraft is grounded until its machinations have received a full factory overhaul from an authorized service center that results in a subsequent favorable inspection to confirm flight worthy operation. The Ground Control Station, when used, also undergoes preflight diagnostics. All maintenance must be included in the aircraft log book that is maintained after each scheduled flight.

All UAS undergoing maintenance that affects operations, i.e. component replacement, must undergo a test flight per the operator’s manual to verify proper operation (see exhibit 4). The PIC performing the functional test flight must document the field study in the UAS aircraft records of the flight. All requirements and procedures for a functional test flight and record entry are to be added to the flight log

. Prior to motion picture filming or similar operations, a scripted test flight demonstration, administered by an operator-sanctioned and pilot, must be conducted, completed, and documented. This document must be available for review upon request by the Administrator. Since the flight qualifications are operator-developed, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioners will conduct these tests in accordance with the operator’ s manual.

The UAS may not overtake any person except for authorized and consenting production personnel below a hazardous altitude in the event of mechanical failure or emergency.

Prior to motion picture filming or similar operations, the PIC must have logged, in a manner consistent with 14 CFR § 61.51 (b), no less than five hours as a UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three takeoffs and three landings in the previous 90 days. All training, experiential, and takeoff and landing currency flights can be performed under this grant of exemption in order to achieve the required flight time and 90- day currency. Throughout any of the aforementioned currency flights, all personnel inessential to flight operations are classified as non-participants, and the PIC must operate the UAS with a distance from non-participants as dictated by 14 CFR § 91.119.

The operator’s manual outlines safety guidelines for consenting production personnel. All present personnel must be essential to closed-set film operations. Due to these procedures, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions in specified distances as prescribed in the petitioners’ manual. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television Filming.The operator is to make sure that non-participating persons are not to come within 500 feet of the area except for necessary, consenting individuals involved in the filming production. If Administrator approves with assurance of no safety risk, this provision may be reduced to no less than 200 feet. In example, an aviation safety inspector may determine an equivalent level of safety of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc.. Any such barriers may protect non-participating persons (public observers, news outlets, etc.) from debris in the event of an accident. Furthermore, this is inline with the same FAA Order 8900.1, V3, C8, S1.

In the event of unplanned interference or an emergency, the UAS must abort flight, per the operator’ s manual.

In the event of UAS communications or GPS signal loss, the UAS must return to a pre-determined location within the security perimeter for landing or recovery, per the operator’ s manual.

Each UAS operation must conclude within 20 minutes flight time or with 25% battery power remaining, whichever occurs first.

The PIC must request a NOTAM no more than 72 hours in advance and no less than 48 hours prior to operations.

Procedural documentation and UAS record maintenance systems are to be developed by the operator, along with documentation of preventative maintenance, alterations, status of replacement component parts, and the total time in the service of the UAS. These documentations and procedures are to be included in the operator’ s manual.

Each UAS operated under this exemption must comply with all manufacturer safety b ulletins.

The preflight inspection must account for all discrepancies, i.e., inoperable components, items, or equipment, as dictated by relevant preflight inspection sections of the operator’ s manual.

The radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements prior to conducting operations.

Three days before scheduled filming, the UAS operator affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The three-day notification may be waived with FSDO approval. The Plan of Activities must include, at minimum, the following:

1 . Dates and times for all flights 2 . Operator name and phone number for the UAS filming production conducted under this grant of exemption 3 . Responsible party of UAS on-screen operation name and phone number 4 . Make, model, and serial or N-number of UAS to be used 5 . Name and certificate number of UAS PICs involved in the filming production event6 . A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; additionally, a list of those who gave permission must be made available, should an inspector request such a list 7 . Signature of exemption-holder or representative

A submission of flight activity description, maps, area diagrams of any city, town, county, and/or state over which filming will be conducted as well as the altitudes essential to accomplish operations will be made to through the proper channels

The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UA will avoid any and all operation within 5 nautical miles of the geographic center of a non-towered airport as suggested on a current FAA-published aeronautical chart, unless, that is, a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The airport management’ s letter of agreement must be made available to the Administrator upon request.

The UAS must remain clear and give the right of way to all other manned operations at all times, including but not limited to other vehicles, and recreational activities such as parachuting, parasailing, hang gliders, etc..

UAS operations may not be conducted at night, as defined in 14 CFR § 1.1. All operations are to be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

Under no circumstance will the UAS be remotely operated by the PIC.

The UAS will not be operated <500 feet or <2,000 feet horizontally from a cloud or when visibility is <3 statute miles from the PIC.

Any 1) incident, 2) accident, or 3) flight operation that offends the lateral or vertical operational area boundaries as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. The National Transportation Safety Board (NTSB), per instructions contained on the NTSB web site: www.ntsb.gov , will be notified immediately should an accident occur. Further flight operations may not be conducted until the incident, accident, or flight offense is reviewed by AFS-80 and authorization to resume operations is granted.

Unless otherwise stated in this grant of exemption, the UAS, PIC, and operator must comply with all applicable parts of 14 CFR including but not limited to parts 45, 47, 61, and 91.

Documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at the UAS’s ground control station any time the aircraft is in operation. Upon request, these documents are to be made available to the Administrator or any law enforcement official.PIC Overview:

Flight Team Cooper Dunn and Floyd Fishel have logged over 150 hours of structured and skilled flight time in the with the DJI Inspire 1 or similar quadcopter device. Initial flight hours were logged using a manual quadcopter call an SQ1. After manual flight techniques were mastered, OP Media LLC invested a DJI Inspire 1 to take advantage of the integrated 4k camera and advanced flight navigation feature set. Since acquiring the Inspire 1, Cooper Dunn and Floyd Fishel have logged just over 150 hours of purposeful flight time to sustain an advanced skill set and generate demo content to be used once an exemption is granted(see exhibit 3). In keeping with best practices, the flight team logs a average of 2.5 hrs per week cultivating flight techniques to enhance our skill-set. Any and all flights granted under this exemption will be flown by said flight team under the terms written here in.

A dedicated and safe systematic approach to flying a UAS is a self-directed training program that is performed away from the public and insures the flight team is prepared and sharp for flying opportunities that appear with short notice. In turn, OP Media LLC would like to be granted an exemption with the understanding that we commit to sustain frequent and varied flights on a monthly basis to maintain flight ready status and insure optimal operation of said DJI Inspire 1. Furthermore, this continued propensity for consistent flights will bring OP Media LLC in line with the target of 240 hours of skilled flight time as a recommended bench mark of mastery. As our exemption is process we will surpass this figure and can update the flight log to reflect this experience and resubmit as needed.

Benefit to Public:

Public benefit is multi-dimensional as our entrance into the commercial market as a for hire aerial videography outfit will provide a legitimate authorized company to serve the thriving corporate/film/ television market in the southeast. In addition, our services will benefit the the greater good of the public by collecting content from a new perspective not previously offered. Furthermore, OP Media LLC. can avail themselves to local municipalities, private industries, and other interested parties in effort to provide cost effective solutions for maintenance and upkeep of public infrastructure, which are safer and provide more frequent coverage vs. tradition helicopter solutions. Even more so, this exemption benefits the public in the sense that the operators contained within have taken the proper steps to educate and train themselves in a manner that places the concern and safety of the public as the top priority in any aerial video production.Summary Request:

As detailed via previous terms and conditions, the partners signed below, seek FAA authorization of said exemption status. In turn, the certificate of authority and certificate of exemption will grant OP Media LLC to operate within the above parameters for compensation or hire within the United States National Air Spa ce.
Respectfully Submitted: /s Floyd Fishel

/s Cooper Dunn



### Exhibit	1	-	DJI	Inspire	1

### Exhibit:	2	Cooper	Dunn	Flying	DJI	Inspire	1