February 29 , 2016

US Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations fro m: 14 CFR 61.113(a) & (b); 91.7(a); 91.103; 91.119 (c); 91.121; 91.151 (a); 91.405(a); 91.407(a)(1); 91.409(a) (1) and (2) ; 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, I, Leslie Thompson,
operator of an Unmanned Aircraft System (UAS) , hereby apply , on behalf of PhotogBuddies LLP,for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so 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.

I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b) , 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) an d (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 proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the purposes of conducting aerial photography, and videography for events (public & private), real estate photography (commercial and residential)

, structural and roof inspections, construction site updates, cinematography , agriculture, landmarks, data collection, tourism and promos, surveying, marketin g/advertising, news gathering, and assisting local media.

Applicant: Ms. Leslie Thompson Partner PhotogBuddies LLP 1903A Muny Vista Ct Alton, IL 62002 photogbuddies@gmail.com 618

- 606

- 2097

Commercial operation of an UAS, as described herein, which are equipped with camera and sensors, would operate in the following manner: * A erial photography for public and/ or private use including events, real estate (commercial and private), structural and roof inspections, construction site updates, agriculture, landmarks, data collection, tourism and promos, surveying, marke ting/ advertising, news gathering, and assisting local media, and other related professional activiti es. * Aerial videography for public and/ or private use including events, real estate (commercial and private), structural and roof inspections, construction site updates, agriculture, landmarks, data collection, tourism and promos, surveying, marketing/advertising, news gath ering, and assisting local media, and other related professional activities.As described fully below, the requested exemption would permit the operation of a UAS under controlled

conditions in the NAS that would be a) limited, b) controlled, c) predetermi ned, and d) provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation responsibilities to “...establis h requirements for the safe operation of such aircraft systems in the national airspace system.”

As found in Exemption No. 14790 (Anstine, Drone Difference LLC), the FAA recently approved similar use of a Yuneec Model Q500 Typhoon UAS. We will operate UAS (s), the Yuneec Model Q500 Typhoon, the DJI Phantom 3 Professional, which are comprised of an unmanned aircraft (UA or Typhoon, and/ or Phantom), an attached 4K camera and a transportable ground station. The Yuneec Typhoon Q500 is a quad

- copter with a gros s weight of 60.0 oz. (3.75#s). It is equipped with four rotors that are driven by electric motors powered by batteries. The Typhoon has a maximum airspeed of 9.84 m/s. The Phantom 3 is also a quad

- copter w ith a gross weight of 44.8 oz. (2.8#s). It is equipped with four rotors that are driven by electric motors powered by batteries. The Phantom has a maximum airspeed of 16 m/s. They will be operated over various metropolitan areas to augment real estate listing photos/ videos, capture event areal video and p hotography, and related business operations.

**UAS Operating Parameters** We will abide by the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:

 Operate UAS below 4 0 0 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual observation;

 Obtain permission from the owner/ controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard;

 Operate the UAS for 5

- 12 minutes per flight;

 Land the UAS prior to the manufac turer’s recommended minimum level of battery power;

 Operate UAS during daylight hours only within visual line of sight (VLOS);

 Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

 Conduct all operations under the flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

- Remain Back 150 feet” ) and will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;

 Contact respective airports if operations will be within 5 miles to advise them of our UAS’ estimated flight time, flight duration, elevation of flight and other pertinent information;

 Alway s obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event of safety breaches or potential danger;

 Only operate in safe environments that are strictly controlled, are away from power lines, elevated lights , airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO);

 Conduct extensive preflight inspections and prot ocols, during which safety carries primary importance.Regarding UAS operational training, we have flown numerous practice flights in remote areas as

hobbyists simulating flights for future commercial use to gain familiarization with the characteristics o f the UAS’ performance under different temperature and weather conditions.

Any PIC (Pilot in Command) operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

-rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations. In addition to the hour requirements, the PIC will accomplish 3 take

- offs and landings in the preceding 90 days (for currency purposes) prior to any flight.

**Specific Exemptions Requested** Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operations, this regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we will perform preflight inspection of the UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and gi ven its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/ flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of 4 00 feet above ground level (AGL) and will also only operate in safe areas away from the public an d traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the size, weight maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two lo w battery alerts are issued

- per the operating documents, the UAV will be landed at the first alert. Also, our flights will last only 5

- 12 minutes each, and the UAS has an automatedfunction, which results in immediate landing when a low battery is detecte d. The PIC will not begin a

flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

**Public Int erest**  Aerial photography and videography for events and real estate are proven strategies to enhance marketing efforts and increase business success. The industry is not new. However, until recently it was conducted through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting this exemption, I would be able to provide affordable services.

Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel when comp ared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to the environment and benefit economic growth by providing information to companies and the public looking to relocate or build in the metro areas where we provide s ervices such as cinematography, news gathering, agriculture, landmarks, data collection, structural and roof inspections, construction site updates, tourism and promos, surveying, marketing/advertising, and assisting local media. Private and public events serviced by our business enhance vibrancy and add culture to the community and its citizens.

**Summary** We will comply with all of the following conditions and limitations should this exemption be provided: 1) Operations will be limited to the following aircraft described in the operating documents, which is a quad

-rotor aircraft weighing 60oz (3.75#s): Yuneec Q500 Typhoon Unmanned Aircraft System; a quad

-rotor aircraft weighing 44.8oz (2.8#s): Phantom 3 Unmanne d Aircraft System. 2) The UA will not be flown at an indicated airspeed exceeding 50 knots. 3) The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), all altitudes reported to ATC must be in feel AGL. 4) The UA will be operated wi thin visual line of sight (VLOS) of the Pilot in Command (PIC) at all times. 5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents

. 6) The operati ng documents will be accessible during UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request. 7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for saf

e flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records. 8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristi cs, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records. 9) The pre

- flight inspection section in the operating documents will accoun t for all discrepancies, i.e. inoperable components, items or equipment, not already covered in the relevant sections of the operating documents.10) We will follow the UAS manufacturer’s aircraft/ component, maintenance, overhaul,

replacement, inspection, and life limit requirements. 11) We will carry out maintenance, inspections, and record keeping requirements, in accordanc e with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12) Each UAS operated will comply with all manufacturer Safety Bulletins. 13) An authorized person will make an entry in the aircraft record of the correcti ve action taken against discrepancies discovered between inspections. 14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a current third

- class medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 15) Prior to operations conducted for the purpose of aerial videography/ photography and for real estate listing and videos and public and private events and cinematography, news gathering, agriculture, landmarks, data collections, structural and roof inspections, construction site updates, tourism an d promos, surveying, marketing/ advertising, and assisting local media , and similar operations, the P IC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

-rotor UAS. 16) Prior to operations conducted for the purpose of aerial videography/ photography and for real estate listing and videos and public and private events and cinematography, news gathering, agriculture, landmarks, data collections, structural and roof inspections, construction site updates, touris m and promos, surveying, marketing/ advertising and assisting local media, and similar operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours of UAS pilot operating the make and model of the UAS to be used in operations. The PIC will accomplish 3 take

- offs and landings in the preceding 90 days. 17) The PIC will not operate the UAS for the purpose of aerial videography/ photography and for real estate listing videos and public and private events and cinematography, news gathering, agriculture, landmarks, data collections, structural and roof inspections, construction site updates, tourism and promos, surveying, marketing/ advertising and assisting local media, and similar operations, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC). 19) The UA will not operate within 5 nautical miles of an airport ref erence point as denoted on a current FAA

-published aeronautical chart. 20) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 21) If a UA loses commun ications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22) The PIC will abort a flight in the event of unpredicted obstacles or emergen cies in accordance with the operating documents. 23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver of Authorization

(COA) prior to conducting any operations, and also request a Notice to Air

- man (NOTAM) not more than 72 hours in advance, but not less than 48 h ours prior to the operation. 25) Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request. 27) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 28) The UAS will not be operated by the PIC from any moving device or vehicle. 29) The UA will not be operated over congested or densely populated areas. 30) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/ or debris in the event of an accident. We will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/ o r; b. The aircraft is operated near vessels, vehicles or structures where the owner/ controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those person per § 91.119(a). 31) All operations will be conducted over private or controlled

- access property with permission from the land owner/ controller or authorized representative. Permission from land owner/ controller or authorized representative will be obtained for each flight to be conducted. 32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NT SB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

If you have any questions or need additional information, please contact me at photogbuddies@ gmail.com or (618) 606

- 2097.

Thank you,

Ms. Leslie Thompson Partner PhotogBuddies LLP