Sept 11, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and C.F.R. Part 

11, Chipkagraphy, LLC. owner and operator of Small Unmanned Aircraft Systems (UASs), Aerigon IAH3, 

Freefly Alta, DJI S1000+, DJI S900, DJI S800 EVO, DJI Inspire 1, DJI Phantom 3, and DJI Phantom 2 Vision 

+ requests to be exempted from the Federal Aviation Regulations (FARs) listed below so Chipkagraphy, LLC. 

may operate UASs commercially in airspace regulated by the Federal Aviation Administration; as long as such 

operations are conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by section 333.

The Name and address of the applicant is: 

Chipkagraphy, LLC.

Attn: Bryan Chipka

3459 Knoll Crest Ave.

View Park, CA 90043

chipkagraphy@gmail.com

310.902.2339

As described below, the requested exemption would permit the operation oflightweight (less than 55 lbs. total take 

off gross weight) UASs under controlled conditions for commercial use by professional certificated pilots thereby

enhancing safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to “....

establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 

333(c) of the Reform Act.

Chipkagraphy, LLC. respectfully requests the grant of an exemption tothe following specific sections of the Title 

14 Code of federal Regulations allowing it to operate lightweight UAS's for commercial use:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 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)

Chipkagraphy, LLC. Submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking 

relief from any currently applicable FAR's operating to prevent SCI’s future commercial use of small UASs to 

operate in the national airspace system as described below. The Reform Act Section 332 provides for such 

integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do 

so. SCI’s lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and 

therefore the integration of SCI’slightweight UASs are expressly contemplated by the Reform Act. SCI would 

like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAAto 

promulgate rules governing suchaircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems

may operate safely in the national airspace system (NAS) before completion of the rulemaking required under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types 
of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security 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

• Operation of the UAS within visual line of sight of the operator Reform Act 333(a)

If the secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary 

shall establish requirements for the safe operation ofsuch aircraft in the National AirspaceSystem." Chipkagraphy, 

LLC. UAS’s are rotorcraft weighing less than 55 pounds including payload. They operate at a speed of less than 

50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS 

will operate only within the line of sight of the pilot within a protected flight area as described below. Such 

operations will insure that the UASs will not create a hazard to the users of the national airspace system or the

public.

The small nature of the UASs utilized by Chipkagraphy, LLC. combined with the safety protocols outlined below 

will allow for a greater than equivalent level of safetyin which Congress envisioned that the FAA must, by 

exemption allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and

the areas and altitudes they will operate, approval of the exemption presents no national security issue and 

absolutely minimal safety concerns which have been mitigatedthrough a rigorous risk management process. Given 

the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, the significant public benefit, 

including enhanced safety, reduced emissions utilizing UASs verse traditional aircraft as well as the economic 

impact of greatly reducing the cost of aerial photography thereby benefiting the greater public's interest. 

Accordingly, the applicant requeststhat the FAA grant the requested exemption without delay.

The following limitations are considered to be binding for the operation of UASs for commercial purposes by 

Chipkagraphy, LLC

1. Flights will be operated in the line-of-sight by a ground-based pilot

2. Flights will only occur in the daytime and clear of clouds

3. The UASs will weigh less than 55lbs at take off and during flight

4. Flights will be terminated with 25% of battery life remaining

5. Flights will be operated at an altitude at or below 400' AGL

6. Pilots, camera operators and observers will be trained as to the applicable portionof the UAS's manual

as well as the SOPs.

7. Minimum UAS crew will be one certificated Commercial pilot or higher rating with a current FAA 

medical. A camera operator and or observer may be added as required to further reduce the possibility of 

task saturation by the pilot depending on the mission requirements.

8. Pilot, observer and camera operator will maintain real time communication capability throughout flight

operations.

9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility (AOR). This AOR is 

the actual area for UAS operations for a particular day. Each survey will include the assessment of potential

hazards to include but not limited to airspace classification, NOTAMS, temporary flight restrictions, closest 

airport proximity, natural and manmade obstacles, and unnecessary persons which may pose a risk to 

operationsor safety. If deemed necessary, the crew will employ additional personal as safety observers.

10. Chipkagraphy, LLC. will employ safety observers as well as sign notifications in areas close to public

activity.

11. A thorough briefing will be conducted, prior to the first flight of the day in an AOR, utilizing the briefing 

guide in the SOPs. All persons who will be in the AOR while UAS flights are conducted will be present 

for this briefing.
12. Chipkagraphy, LLC. will obtain consent (verbal or written) for any persons who need to be within 100 

feet of UAS flight operations.

13. Written and or verbal permission from the relevant property owners will beobtained prior to flight.

14. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire or other governmental agencies.

15. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a 

pre-determined location within the AOR and land autonomously.

16. The UAS will have the ability to abort a flight in case of unpredicted obstaclesor emergencies.

14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203 (a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurementof necessary airworthiness 

certificates in relation to FAR 91.203(a)(1) The size, weightand defined area of operations for SCI UAS flights 

permits exemption from Part 21 because Chipkagraphy, LLC. meets an equivalent level of safety pursuant to

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate

requirement under both the ACT (49 U.S. C. 44701(f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of 

weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Chipkagraphy, 

LLC. meets or exceeds each of theseelements.

14 C.F.R. 91.203 (a & b) provides for carrying of civil aircraft certifications and registrations. They are 

inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining 

such certifications and registrations at Chipkagraphy, LLC. flight operationscenter.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate

will be applicable in the form contemplated by the FARs, this regulation isinapplicable.

14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots of passengers, and 

given the size of the UASs, this regulation is inapplicable.An equivalent level of safety will be achieved by 

maintaining an operators manual atthe flight operations center. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

10700 and 32827.

14 C.F.R. 91.103(b) Preflight actions

14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include: (b) For any flight, runway lengths at airports of

intended use, and the following takeoff and landing distance information. This subparagraph is not applicable due 

toour off airfield operations.

14 C.F.R. 91.109 Flight instructions; simulated instrument flight and certainflight tests.

14 C.F.R. 91.109 and all the subparagraphs address the operation of a civil manned aircraft in conjunction with 

training and flight tests. The UAS to be employed by Chipkagraphy, LLC. are not designated in thiscategory.
14 C.F.R. 91.121 Altimeter Settings

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Chipkagraphy, LLC UASs utilize GPS 

systems and internal gyroscopes to provide spatial stabilityand a reference datum.

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions

14 C.F.R. 91.151 prohibits an individual from beginning a "flight in an airplaneunder 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.

The battery powering the UAS provides approximately 15 minutes of powered flight, which is less than the 

reserve requirement alone by FARs for day. Given the limitations on the UAS's flight envelope, proposed AOR 

size, battery life and its ability to land immediately it is reasonable to allow an exception.

An equivalent level of safety can be achieved by limiting flights to 25% of battery power. This restriction would be 

more than adequate to return the UAS to its planned landing zone in the AOR.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 and 10808.

14 C.F.R. 45.23 Marking of the Aircraft

Applicable Codes of Federal regulations require aircraft to be marked according to certain specifications. SCI 

UASs are unmanned; do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. 

Further, two-inch lettering is impractical to place on such small aircraft. Chipkagraphy, LLC. will,however, place 

the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. 45.29 (f)so that the pilot, camera operator, 

observer and any other persons operating in the AORcan see the markings on the UAS. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 A, and 10700.

14 C.F.R. 91.119 Minimum Safe Altitudes

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at 

lower altitudes in certain conditions. Chipkagraphy, LLC. will only operate its UASs at or below 400 AGL. 

Chipkagraphy, LLC. will operate its UASs in a defined AOR that has been carefully reviewed for hazards and 

minimizes the presence of any persons not essential for operations. Flights will only be conducted over private

property with consent of the property owner. The equivalent level of safety will be achieved given the size, weight

and speed of the UAS as well as the location where it is operated. Compared to flight operations with traditional 

aircraftor rotorcraft weighing far more than 55lbs, operating below 500 AGL with flammable fuel UAS operations 

present a far smallerrisk.

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 theaircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as prescribed in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter, and others shall inspect or maintain the aircraft

in compliance with Part 43.

These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to 
Chipkagraphy, LLC. UASs should its requested exemption be granted. As an equivalent level of safety 

Chipkagraphy, LLC. requires its pilotsto conduct a preflight, through flight and post flight inspection of the UAS 

to ensure its flight worthiness prior to launch. Each UAS is flown in compliance with the applicable manufactures 

manual to include all software update cycles as well as flight checklists. In the event of a malfunction the UAS can 

land immediately.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent and

knowledge.

Summary

Chipkagraphy, LLC. is seeking exemption from the following rules:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 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).

Approval of the above exemptions allowing commercial operations of small UASs in the service of aerial 

photography will greatly enhance safety by reducing the overallrisk associated with traditional aircraft. Traditional 

aerial photography requires large aircraft weighing thousands of pounds and carrying hundreds of pound of fuel 

presenting a significant risk to life and property. With Chipkagraphy, LLC.'s use of small UASs weighing less than 

55 lbs., powered by batteries and operating at or below 400 AGLthey virtually eliminate all of the risk associated 

with traditional aerial photography. The UASs will carry no people thereby eliminating the exposure to the risks 

associated with flying while accomplishing the same task in a much safer manner.

Granting Chipkagraphy, LLC. the above exemptions will allow for the expansion of UAS systems into the future, 

in a professional, safety conscious culture steep in the tradition of Aviation. The safety culture established by the 

founding members of Chipkagraphy, LLC. is based on our 15+ years of business experience.

Chipkagraphy, LLC. respectfully requests that the FAA grant its exceptionwithout delay. The FAA has the 

authority to issue the exemption sought by Chipkagraphy, LLC. pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958), as amended (the "Act").

Sincerely,

Bryan Chipka

Chipkagraphy, LLC.

3459 Knoll Crest Ave.

View Park, CA 90043

chipkagraphy@gmail.com

310.902.2339