Brandon W

oods Nathan W

aters 125 W almart W ay Suite 8 Wi lliamsburg, KY

40769 606

- 521

- 9423/606

- 344

- 4616 FA X: 606

- 549

- 1323 nwaters82@gmail.com
U.S. Department of T

ransportation Docket Management Sy stem 1200 New Jers ey

Av e., SE Wa shington, DC 20590 RE: Exemption Request Section 333 of the F AA Reform Act Dear Sir or Madam: Pursuant to Section 333 of the F AA Modernization and Reform Act of 2012, we are the planned operator of Small unmanned Aircraft Sy stem (sUAS) equipped to conduct aerial photography , video, and survey

for various industries hereby applies for an exemption from Federal Av iation Regulations (F AR) to allow commercial operation of their sUAS, so long as such operations are conducted within and under th e conditions outlined herein or as may be established by the F AA as required b y Section 333. Contact information: Brandon W

oods Nathan W

aters 125 W almart W ay Suite 8 Wi lliamsburg, KY

40769 606

- 521

- 9423/606

- 344

- 4616 FA X: 606

- 549

- 1323 nwaters82@gmail.com Equipment: DJIPhantom 3 Advance The specific section or sections of 14 CFR from which we seek an exemption: Exemption Request Pursuant to Section 333 of the FMRA and Part 1 1 of the Federal Av iation Regulatio ns, Seeking Exemption from: 14 CFR Part 21 Subpart H 14 CFR 91.1 19 (c) 14 CFR 91.121 14 CFR 91.151 14 CFR 91.405 14 CFR 91.407 (a)(1)14 CFR 91.409(a)(1) and (2)

14 CFR 91.417(a) and (b) The extent of relief and the reason we seek the relief:
W e are submitting this application in accordance with the Reform Act, 1 12 P .L . 95 §§ 331

- 334, seeking relief from an y currentl y applicable F ARs operating to prevent us from commercial cinematic, academic and other flight operations within the national airsp ace sy stem. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national airspace s ys tem as it is in the public's interest to do so. Our sUAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of our sUAS is covered under the Reform Act. W e would like to operate our sUAS prior to the time period to the time period by which the Reform Act requires the F

AA to promulgate rules governing such craft. Th ereby , providing direct experience and valuable information for formal regulation that can be administered uniformly to all related sUAS aerial video and photography . The Reform Act guides the Secretary in determining the ty

pes of sUAS that may operate saf

el y i n our national airspace s ystem. Considerations include: The weight, size, speed and overall capabilities of the sUAS's; whether the sUAS will be operated near airports or heavily populated areas; and, Whether the sUAS will be operated b y line of sight . 1 12 P.L . 95 § 333 (a). Each of these items reflect in favor of an exemption. Our sUAS utilizes four ( 4) counter

- rotating propellers for balance, control and stability . Our sUAS is equipped with GPS and auto return safet y technology

. We ighing less than three (3) pounds {far below the maximum 55 pound limit); including pay load.
We will concider safet y as foremost with each flight. Built in safety s ys tems include a GPS mode that allows our sUAS to hover in place when radio controls are released. When pilo t communication is lost sUAS is designed slowl y descend to point of takeof f. W e do not operate sUAS near Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) feet depending on location, conditions and weather. W e constantl y are on alert for an y m anned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach our location or we suspect manne d aircraft may approach near our location. Our sUAS is capable of vertical and horizontal operations, and are flown only within my

line of sight and m y visual observer (VO), as the remote control pilot. Utilizing battery power rather than combustible fuels , flights generally last between five (5) to twenty (20) minutes, with an altitude generally

under two hundred (200) feet. We utilize a fresh fully charged battery with each flight as a safet y precaution; full flight time limit for each battery Is (25) min utes as tested. W

e do not operate our sUAS at or below manufacture recommend minimum charge levels for operations; preferring to remain well within a safe operating range to insure adequate communication between radio control and sUAS to eliminate potenti al for crash, loss of control or hazard. We do not believe in taking risk that may

cause a crash that could create hazard to the public, property , or other manned aircraft. W

e have logged numerous practice flights in remote areas as a hobby ist simulating flights for future commercial use to gain familiarization with the characteristics of this specific sUAS's performance under different temperature and weather conditions. W e also practice computerized simulated flights to maintain adequate skills and respo nse reflex time. All for the sake of safet y. We are extremel y cautious when operating our sUAS so we will not "create a hazard to users of the national airspace s ys tem or the public." 1 12 P.L . 95 § 333 (b). Given the small size and weight of this sUAS's it falls well within Congress's contemplated safet y zone when it promulgated the Reform Act and the corresponding directive to integrate sUAS's into the national airspace s ys tem. We have used the sUAS in hobby

flight, has a demonstrable safet y record and d oes not pose any threat to the general public or national security

.How the request would benefit the public as a whole:

Aerial videograph y for geographical awareness has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies the expense of such aerial videography is cost prohibitive. Only

large companies can af

ford to absorb such expense. Depriving lower budget business from a valuable marketing tool. Our sUAS pose no threat since size and lack of c ombustible fuel alleviates an y potential threat to the public. Congress has alread y proclaimed that it is in the public's interest to integrate commercially flown sUAS's into the national airspace s ys tem, hence the passing of the Reform Act. Granting our e xemption request furthers the public interest through academic/visual awareness of the geographical benefits. Our sUAS is battery powered and creates no emissions that can harm the environment. The consequence of our sUAS crashing is far less than a full s ize helicopter or fixed wing aircraft; which contain combustible fuel and can cause catastrophic devastation to the public. The public's interest is furthered b y minimizing ecological and crash threat by permitting aerial video/photo capture through our battery operated sUAS. Permitting our request to immediately fl y within national air space furthers economic growth. Granting our exemption request substantially furthers the economic impact for the companies looking to relocate or build as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community

. Reasons wh y the exemption would not adversel y aff ect safety , or how the exemption would provide a level of sa fety

at least equal to the existing rule: Our exemption will not adversel y affect safety . Quite the contrary

, for the reasons stated permitting us to log more flight time in F AA controlled airspace, with communication with the F AA, will allow us to contr ibute to the innovation and implementation of new and novel, as of ye t undiscovered safet y protocols development in cooperation with the F AA. • sUAS weighs 2.8 pounds including pay load. • sUAS will not exceed 35.7 MPH (31.105 Knots). • Ionl y operate m y sUAS well within the 200 foot permissible ceiling. • My sUAS will only

operate for 5

- 15 minutes per flight. • My sUAS meets or exceeds all FCC requirements."~ • W e land my UAS prior to manufacturer recommended minimum level of battery power
. • W e pil ot my

UAS through remote control onl y by line of sight of the PIC and the visual observer

. • Our UAS has GPS a flight safet y feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost. • W e activel y anal yz e flig ht data and other sources of information to constantly update and enhance safet y protocols. • W e only operate in reasonably

safe environment that are strictl y controlled, are away from power lines, elevated lights and activel y populated areas. • W e condu ct pre

- flight inspections, during which safet y carries primary importance. • W e alway s obtains all necessary permissions prior to operation Our safety

protocols provide a level of safet y equal to or exceeding existing rules. • First, the potential loss of life is diminished because UAS's carry no people on board and we onl yoperate our UAS in specific areas away from mass populations. • Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. • Third , the small size and extreme maneuverability of m y UAS allow us to remotely pilot away from and avoid hazards quickly and safel y. • L astly , given its small size and weight, even when close enough to capture amazing images, our UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly

, our UAS has been experimentall y operated for familiarization/competency and will continue to operate at and above current safet y l evels. Any additional Information, views or argument available to support y our request. Currently , area awareness and aerial videograph y/ photograph y relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to th e public. Granting our request for exemption will reduce current risk levels and thereby enhance safety

. Our sUAS craft does not contain potentially

explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. W e respectfull y request that the F AA grant m y exemption request and am willing to cooperate in sharing information to benefit the F AA, safet y of manned aircraft, and the general public at large.