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December 14, 2015

F5 Graphics, Inc. 6245 Indian Trail Drive Loxahatchee, FL 33470 (561) 795

- 4826
Email: F5Graphics@att.net

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 2059

Reference: Docket No. FAA

- 2015

- 4253

T his is an update to our exemption request Docket No. FAA

- 2015

- 4253 addressing the issues of:

 The reasons why the exemption would not adversely a ffec t safety or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek an exemption.

 A ny additional information, views, or arguments available to support your request.

First, the potential loss of life is diminished because UAS carry no people on board and will be operated in specific areas away from mass populations. Secon d, there is no fuel on board the UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size an d extreme maneuverability
of a UAS allows it to be remotely piloted away from and avoid hazards qu ickly and safely.

F5 Gr aphics, Inc. considers safety of ut most importance with every flight. The DJI Phantom 3 Professional is designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability and fear of financial loss F5 Graphics, Inc. will not fly in winds exceeding 14 knot (15 mph). Built in safety systems include a GPS mode that allows DJI Phantom 3 Professional to hover in place when radio controls are released. When pi lot communication is lost, the UAS is designed to slowly descend to point of take

- o ff. The DJI Phantom 3 Prof es s ional utilizes battery power rather than
combustible fuels

. F5 Graphics, Inc. utilize s a fresh fully charged battery with each flight as a safet y precaution; full flight time limit for each battery is twenty (20) to twenty

- five (25) minutes as tested , this offers little or no risk to national security. The UA S , powered by batteries, is smaller, lighter and more maneuverable than larger aircraft run ning on combustible fuel with no people on board thereby reducing current risk levels and enhancing public safety. Due to the small size of the DJI Phantom 3 Professional

, the material with which the DJI Phantom 3 Professional is built and its specific safety procedures (amongPage 2 of 3

others ground detection), the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption.

The safety and reliability of the DJI Phantom 3 Professional is supported by the fact that numerous FAA exemptions have previously been approved for t heir use in commercial operations.

F5 Graphics, Inc.’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, fixed winged aircraft and helicopters are the primary means of aerial photography and videography. While the

s a fety record of such aircrafts are remarkably astounding, there has been incidents involv ing loss of life as well as extensive property damage; it is far safer to operate a bat tery powered ultra

- lightweight UAS. The unmanned aspect of aerial technology eliminates the endangerment of human life by allow ing low and slow flight and permit s a safe and cost

- effective acquisition of close

- up aerial images.

F5 Graphics, Inc. has personally instilled safety protocols and controls to avoid and prevent public hazard, as well as interaction with man n e d aircraft

. F5 Graphics, Inc. use of the DJI Phantom 3 Professional will be subject to the following operating conditions, which are based on the operating conditions set forth by the Academy of Model Aer onautics . The main restrictions are summarized below:

 Operations to be conducted over private, controlled

- access, or public property where

approved;

 Permission from the land owner/authority required before commencing any flight;

 Operations over congested areas shall be avoided;

 Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times

 Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours

 Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all times;

 Flight ceiling pre

- programed at maximum 400 feet;

 All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;

 All operations shall comply with required permissions and permits establishe d by territorial, state, county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies.

For the reasons stated in our exemption request of July 13, 2015 ( Docket No. FAA

– 2015

- 4253 )

, F5 Graphics, Inc., respectfully request the grant of an exemption to be allowed to operate ultra

- l ight weight, remote controlled UAS for the purposes of acquiring aerial photos & videos, both of which will promote local economic growth through increased employment and increased tax base. Both performed with public safety in mind by utilizing a safe ultra

- lightweight UAS as an alternative to manned aircraft

conta ining combustible fuel that poses potential public hazard during low and slow flight.Page 3 of 3

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial photography and videography captured thro ugh F5 Graphics, Inc. bat tery operated ultra

- lightw eight UAS's. Permitting F5 Graphics, Inc., to immediately fly within national air space furthers economic growth. Granting this exemption request substantially furthers the economic impact for the South
F lorida area for companies looking to use aerial photography and videography, both of which serve as a stimulus to the community.

Granting F5 Graphics, Inc.’s request comports with the Secretary of T ransportation’s (FAA Administrator’s) responsibilities and a uthority to not only integrate UAS into the national airspace system, but to “...establish requirements for the safe opera tion of such aircraft systems [UAS ] in the national airspace system” u nder Section 333(c) of the Ref orm Act specific to the use of UAS for photography, videography and aerial data collection purpo ses. Further F5 Graphics, Inc. will conduct operations in compliance with the protocols described herein or as otherwise establ ished by the FAA.

Respectfully submitted,

F5 Graphics, Inc.
Jozie M. Felicella
Donald J. Feli cella