February	17,	2016

Docket	Management	System

1200	New	Jersey	Ave.,

Washington,	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	ad	Part	11	of	the Federal	Aviation	Regulations.

Dear	Sir	or	Madam:

Pursuant	to	the	Section	333	of	the	FAA	M odernization	and	Reform	Act	of	2012	(the “Reform	Act”) ,	Jonathan Stokoe	(the	“Applicant”),	sole	operator	of	an	Unmanned Aircraft	Systems	(“UAS”)	requests	an	exemption	from	the	Federal	Aviation Regulations	(“FARs”)	to	permit	commercial	operation	for	aerial photography	and videography	of	real	es tate,	regular	homes,	landscapes, public	and	private	events	in

Tucson

, Arizona	and	surrounding	areas

, as	long	as	the	operations	are	performed

within	and	under	the	c onditions	outlined	here and/ or	as	established	by	the	FA A	as required	by section	333. The	UAS	I	will	be	piloting	is	a	DJI	Phantom	2.

My	family	has	been	in	the	real	estate	business	for	15	+	years .	M y	wife	and	I	are	both

licensed	real	e state	agents	in	Arizona and have	a	desire	to	use	my	UAS	to	help

market	not	o nly	our	own	listings,	but also many	listings	for	my	fellow	industry professionals

. I	am	currently	a	student	with	Arizona	Ultralight	Aviation	and	will have	my	sport	pilot	license	within	the	next few months. My	wife	and	I	are	the	proud

owners	of	Stokoe	Pho to	LLC	and	once I obtain	my	Sport	Pilot	Certificate and FAA exemption. I plan	to	use	this	license	to	pilot	my	DJI	Phantom	2	to	provide	real	estate photography	and	videography	to	my	community.

With	this	new	technology	there	is	no	longer	a	need	for	planes to	go	in	the	sky	with photographers	inside,	which	can	put	many	lives	at	risk	because	of	the	combustible material	and	flammable	liquids.	Using	our	UAS	also	limits	the	risk	of	planes	crashing and	keeps	the	public	safe.	There	will	be	no	explosives	in	the	UAS along	with	no pilots,	nor	photographers.	This	makes	it	much	less	of	a	safety	concern	for	the	public because	my	piloting	of	the	UAS	is	less	hazardous	than	the	previously	used helicopters	or	planes.

By	providing	these	services	to	our	market	in	Tucson,	Ari zona,	I	will	be	adding	to	the growing	economy	and	benefiting	the	public	while	keeping	them	safe	with	fewer pilots	needing	to	fly	small	aircraft	to	accommodate	aerial	photographers.I,	Jonathan	Stokoe,	will	be	the	sole	operator	of	the	DJI	Phantom	2	and	b ecause	of	the advanced	take	off/land	capabilities,	with	advanced	safety	features,	and	with	our companies	Standard	Operating	Procedures	I	know	I	will	be	able	to	conduct	each flight	safely	and	without	error.	All	UAS	operations	will	be	in	accordance	with	Stok oe Photo’s	Standard	Operating	Procedures	or	as	established	by	the	FAA.

The	Name	and	address	of	the	a pplicant is :

Stokoe	Photo	LLC Jonathan	Stokoe 8701	E.	Tanque	Verde	Rd	#75 Tucson,	Arizona	85749

Stokoe	Photo kindly requests	the	grant	of	an	exemption for	the	follow ing	sections	of

the	Title	14	Cod e	of	F ederal	Regulations	allowing	it	to	operate	the	UAS	DJI	Phantom

2	for	commercial	use.

Regulations	from	which	the	exemption	is respectfully requested:

14	CFR	Part	21 Subpart	H

14	CFR	45.23	(b)

14	CFR	91. 7	(a)

14	CFR	91.9	(b)	(2)

14	CFR	91.103 (b)

14	CFR	91.109

14	CFR	91.119

14	CFR	91.121

14	CFR 91.151(a)

14	CFR	91.203	(a)	and	(b)

14	CFR	91.405	(a)

14	CFR	91.407	(a)	(1)

14	CFR	91.409	(a)	(2)

14	CFR	91.417	(a)	and	(b)Specific	sections	of	14	CFR of	which	I	seek	relief	and	why:

14	CFR	Part	21 Subpart	H:	Airworthiness	Certificates

The	UAS	that I will	be	operating	carries	no	pilot	or	passenger,	carries	no	explosive materials	or	flammable	liquids. I ,	Jonathan	Stokoe, request	an	exemption	because	of the	size,	weight,	speed,	and	limited	operating	area	ass ociated	with	the	aircraft. In the	restricted	environment	and	under	the	conditions	proposed	operation	will	be	at least	as	safe,	or	safer,	than	a	conventional	aircraft	operating	with	an	airworthiness

ce rtifi cate	without	said	restrictions	and	conditions	proposed.

14	CFR	45.23	(b) Display	of	marks;	general.

This UAS	does	not	have	a	cockpit,	cabin,	or	pilot	station	on	which	to mark	certain words	or	phrases	due	to	the	size	of	the	DJI	Phantom	2.	Being	tha t	the	UAS	is	so	small the	minimum	2	inch	lettering	would	not	fit	on	my	DJI	Phantom	2. I	request exemption	from 14	CFR	45.23	(b) because	I	will	not	be	able	to	comply	with	putting large	lettering	on	my	small	UAS.	The	lettering	I	will	put	on	my	UAS	will	need to	be smaller	than	the	required	minimum.	I	understand the	importanc e	of		the	lettering

and	because	of	this I	will	mark	my UAS	with	the	largest	possible letters	by	pl acing the	word	“Experimental”, assigned	number	or	name,	based	on	the FAA’s	request ruling

, plus	our	registration	number	from	when	I	registered	my	drone,	on	the	UAS

. The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	m arked as required.

14	CFR	91.7	(a) Airworthiness	Certificates

Because	there	will	be	no	certificate	for	the	airw orthiness	for	my	UAS

, if	this exemption	is	granted

, there	will	be no	FAA	regulatory	standard existing	to determine	airworthiness.	An	equivalent	level	of	safety	will	be	provided	for	the aircraft	for	maintenance.	Also	an	equivalent	level	of	safety	is	provid ed	due	to	the safety	checklist	I	go	through	before	each	flight.

14	CFR	91.9	(b)	(2) Civil	Aircraft	Flight	Manual	in	the	Aircraft

My	DJI	Phantom	2	is	a	small	UAS	and	because	of	the	size	and	configuration	it	is unable	to	carry	a	flight	manual	on	the	air craft.	There	is	no	place	on	board	to	even carry	a	pilot	and	because	of	this	there	is	no	way	for	a	flight	manual	to	be	on	the aircraft.	I	am	requesting	exemption	from	14	CFR	91.9	(B)	(2)	because	I	will	not	be able	to	carry	a	flight	manual	on	my	UAS. An	equi valent	level	of	safety	will	be maintained	by	keeping	the	flight	manual	at the	take	off	point	where	the	operator

will	be	able	to	have	access	to	it	at	a	minutes	notice.14	CFR	91.103 (b)	Preflight	Action

I	request	exemption	from 14	CFR	91.103 pursuant	to	“ 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	la nding	distance

information:” Because	of	the	characteristics	of	my	UAS	it	does	not	need	a	runway	and	because	of that, 14	CFR	91.103(b) is	inapplicable. My	typical	preflight	procedure	consists	of	but	is	not	limited	to;	flight	battery requirement,	landing	a nd	take	off	distances,	reviewing	weather	to	make	sure	it	is	an appropriate	time	to	fly,	along	with	all	of	the	safety	procedures	listed	in	attachment “DJI	Safety	Guidelines”.	All of these	procedures	are	my	equivalent	level	of	safety	for

14	CFR	91.103 (b).

14	CFR	91.109 Flight	Instruction;	Simulated	instrument	flight	and	certain flight	tests.

14	CFR	91.109	and	corresponding	subparagraphs	refer	to	the	operation	of	a	civil manned	aircraft	in	conjunction	with	training	and	flight	tests.	The	DJI	Phantom	2 being piloted	by	Jonathan	Stokoe	are	not	designated	in	this	category.

14	CFR	91.113	(a)	and	(b) Right

- of

- way	rules:	Except	water	operations

I	am	requesting	exemption	from 14	CFR	91.113	(a)	and	(b) because	when	I	am flying	because	it	is	under	400	ft	I	do	not	e xpect	to	encounter	any	other	aircraft	in	the airspace.	The	equivalent	level	of	safety	will	be	if	I	come	upon	another	UAS		I	will	be more	than	able	to	see	and	avoid	them	because	my	UAS	carries	no	pilot	nor passenger.	I	will	land	my	UAS	immediately	until	the other	aircraft	is	no	longer	in sight.

14	CFR		91.119 Minimum	Safe	Altitudes

I,	Jonathan	Stokoe	will make	sure	that	my	DJI	Phantom	2	does	not	operate	higher than	400	feet	at	ground	level. Stokoe	Photo	will	operate	within	its	defined	AOR	that

has	been predetermined	by	our	preflight	assessment. I	will	ensure	that	I	do	not	fly over	congested	areas.	I	always	make	a	pre

- flight	plan	to	ensure	proper	flight	safety and	accurate	height	examination	to	avoid	collisions.14	CFR	91.121 Altimeter	Settings

The DJI	Phantom	2	has	a	GPS	altitude	read	out	which	is	why	I	would	like	an exemption	from 14	CFR	91.121 .	An	equivalent	level	of	safety	is	reached	by	the	live flight	data	that	is	provided when	the	UAS	in	in	flight	which	also	confirms	the	current

altitude	the	U AS	reaches	with	the	GPS	altitude	indicator.

14	CFR	91.151	Fuel	Requirements	for	Flight	in	VFR	Conditions

14	C.F.R.	91.151	does	not	allow	an	individual	from	beginning	a	"flight	in	an	airplane

under	VFR conditions	unless	(considering	wind	and	forecast	w eather	conditions) there	is	enough	fuel	to	fly to	the	first	point	of	intended	landing,	and	assuming normal	cruising	speed

- (1)	During	the	day	to	fly	after	that	for	at	least	30	minutes;	or (2)	At	night,	to	fly	after	that	for	at	least	45	minutes"

Because	th e	battery	that	powers	the	DJI	Phantom	2	provides	approximately	18

minu tes	of	flight	which	is	less	than	the	reserve	requirement	for	day	or	night	VFR flight.	Because	of	the	restrictions	of	the	UAS’s	battery	life	and	because	of	its	ability	to land	immediately it	is	sensible	to	allow	an	exemption. An	equivalent	level	of	safety	is	achieved	by	the	pilot	landing	when	25	%	battery power	is	remaining	on	the	UAS.	This	restriction	would	allow	the	UAS	to	return	to	its planned	landing	zone	in	the	AOR.

14	CFR	91.203	( a)	and	(b) Civil	aircraft:	Certifications	Required.

Similar	to, 14	CFR	91.9	(b) (2) ,	the	DJI	Phantom	2	has	no	ability	to	carry	any certificate	or	registration	documents	on	board	the	UAS.	Because	the	DJI	Phantom	2 is	so	small	and	light	weighted	there	is	no room	or	pilot	on	board	to	adequately	store such	documents.	An	equivalent	level	of	safety	will	be	achieved by	keeping	the documents	with	the	flight	manual	at	the	take off	point	where	the	pilot	has access	to

it	at	a	minutes	notice.

14	CFR	91.405	(a),	14 CFR	91.407	(a)	(1),	14	CFR	91.409	(a)	(2),	14	CFR	91.417 (a)	and	(b) Maintenance	Inspections

Because this	section	only	applies	to	an	aircraft	with	an	airworthiness	certificate; these	sections	do	not	apply	to	this	applicant. For	safety	purposes the	operat or	will perform	preflight	inspections	and	ensure	UAS	is	in	good	working	condition	before conducting each	flight.	Jonathan	Stokoe	is	seeking	relief	from	all	FARs	above preventing	the	applicant	from	conducting	aerial	photography	and	video	of	real

estate	take n	at	levels	less	than	400	ft,	at	a	speed	less	than	33.5	mph,	and	with	a maximum	flight	time	of 15 minutes.The	drone	I	will	be	using	is	a	DJI	Phantom	2.	At	2.5	pounds,	the	weight	of	the	UAS

meets	the	definition	of	“small	unmanned	aircraft”	found	in	sectio n	331	“The	Reform

Act”.	In	order	to attain high	quality photography	and	video	the DJI	Phantom	2 will	be used	at	speeds	much	less	than	it’s	potential	speed	up	to	33	mph. Because the	UAS is battery	powered,	there	are	no	co mbustible	fuels	onboard	the	UAS	whic h	makes	it much	safer	than	the	standard	aircraft	with	flammable	liquids.

The	maximum	flight	time	for	the	UAS	is	15	minutes because	of battery	life.	All	flights will	be	terminated	when	there	is	25%	battery	life	remaining.	Given	the	size,	weight, speed,	an d	limited	operating	area	associated	with	these UAS’s ,	I	find	this exemption to	be	reasonable	with	an	equivalent,	or	greater,	level	of	safety	to	be	reached	by	the

operator.

Safety:

* Please	see	below (also	attached)		“DJI	Safety	Guidelines”	for	safety	pr ecautions I use	for	every	flight.	Aside	from	these	practices	I	have	more	than	200	hours	from hobbyist	drone	flying.	I	am	getting	my	Sport	Pilot	Certificate	currently	in	which	I	am learning	the	different	types	of	airspace	and	from	my	at	least	200	hours	flyi ng experience	I	know	what	types	of	weather	are	safe	to	fly	in	and	which	are	not	which helps	me	make	an	informed	decision	before	every	flight	of	whether	it	is	safe	to	fly	or

not.

We	also	operate	by	the	following	Pre

- flight	Checklist	as	can	be	seen	on	the	D JI	Safety Guidelines	Disclaimer		(Page	2	of	attached	Safety	guidelines	and	disclaimer)

1) “Ensure	that	you	are	using	only	genuine	parts	and	that	all	parts	are	in	mint

condition. 2) Ensure	the	remote	controller,	Intelligent	Flight	Battery,	and	mobile	device

are fully	charged 3) Ensure	that	there	is	no	foreign	object	stuck	to	the	camera	lens,	the	micro

- SD card	has	been	inserted	into	the	camera,	and	the	gimbal	can	rotate	freely before	powering	it	on. 4) Ensure	the	propellers	are	securely	mounted	onto	the	motors,	and	the motors can	start	and	function	normally. 5) Follow	the	on

- screen	instructions	to	calibrate	the	compass. 6) Ensure	the	DJI	Pilot	app	and	aircraft’s	firmware	have	been	upgraded	to	the

latest	version. 7) Ensure	that	your	flight	area	is	outside	the	No

- Fly	Zones	and	fl ight	conditions are	suitable	for	flying	the	aircraft. 8) Be	sure	that	you	are	NOT	flying	under	the	influence	of	alcohol,	drugs	or	any substance	that	may	impair	your	cognitive	abilities. 9) Be	familiar	with	the	selected	flight	mode	and	understand	all	safety	funct ions and	warnings. 10) Be	sure	the	observe	al	local	regulations,	obtain	appropriate	authorizations,

and	understand	the	risks.REMEMBER:	it	is	solely	your	responsibility	to	comply	with	all	flight regulations.”

Additionally:

1) I	land	my	DJI	Phantom	2	prior	to manufacturer	recommended minimum level	of	battery	power(25%) 2) Flights	will	be	piloted	in	the	line

- of

- sight	from	a	ground	based	pilot 3) My	UAS	uses	GPS and	a	flight	safety	feature	whereby	it	returns	to	the location	of	take	off	and	then	slowly	lands	if	communic ation	with	the remote	control	pilot	is	lost. 4) The	UAS	will	weigh	less	than	55	pounds	at	take

- off	and	during	flight 5) I	never	pilot	my	UAS	at	night ,	only	in	daylight	and	clear	of	clouds 6) I	conduct	extensive	pre	flight	inspections	and protocol,	which	helps	me

h ave	a	safe	flight	every	time;	safety is	our	number	one	priority. 7) I	always	obtain	all	necessary	permissions	prior	to	operation 8) I	have	procedure	in	place	to	abort	flights	in	the	even t	of	safety	breaches or	potential	endangerment. 9) I	always	fly	with	my	wife	s he	is	my	VO (Visual	Observer)	and	she	has	been with	me	for	99%	of	my	hobbyist	fligh ts	and	has	extensive	experience,	also she	knows	what	to	watch	for	and	keep	the	drone	away	from	any

obstacles. 10) The	UAS	crew	will	consist	of	the	pilot	Jonathan	Stokoe	and	the VO	Heidi

Stokoe 11) The	pilot	Jonathan	Stokoe	will	conduct	a	pre	flight	to	determine	the	Area of	Responsibility	(AOR)	and	will	also	determine	the	assessment	of potential	hazards	to	include	but	not	limited	to:	temporary	flight restrictions,	closest	airport proximity,	natural	and	manmade	obstacles, and	unnecessary	persons	which	may	cause	a	risk	to	operations	or	safety. 12) Stokoe	Photo	will	obtain	consent	(verbal	or	written)	from	all	those	other than	the	Pilot	or	VO	who	need	to	be	within	100	feet	of	the	operati on. 13) Stokoe	Photo	will	only	conduct	flights	over	private	property	when consent	from	the	property	owner	has	been	obtained.

Stokoe	Photo	respectfully	requests	that	the	FAA	grant	its exemption without	delay. The	FAA	has	the	authority	to	issue	the	exemption sought	by Stokoe	Photo	LLC

pursuant t o	the	Federal	Aviation	Act,	85	P.L.	726	(1958),	as	amended	(the	"Act").Summary: Stokoe	Photo	is	seeking	an	exemption	from	the	following s ections of 14	CFR: 14	CFR	Part	21	Subpart	H ,	1 4	CFR	45.23	(b)

, 14	CFR 91.7	(a)

, 14	CFR	91.9	(b) (2)

, 14	CFR	91.103(b)

, 14	CFR	91.109 ,	14	CFR	91.119, 14	CFR	91.121 ,	14	CFR 91.151(a) ,	14	CFR	91.203 (a)	and	(b)

, 14	CFR	91.405	(a )

, 14	CFR	91.407	(a)	(1)

, 14	CFR	91.409	(a)	(2)

, 14	CFR	91.417	(a)	and	(b)

. By	granting	Stokoe	Photo LLC	an	exemption	to	operate	commercially	in	Tucson, Arizona	it	will	benefit	the	public	as	a	whole. There	will	be	no	explosives	in	the	UAS along	with	no	pilots,	nor	photographers.	This	makes	it	much	less	of	a	safety	concern for	the	public	because	my	piloti ng	of	the	UAS will	be less	hazardous	than	the previously	used	helicopters	or	planes. By	all	of	Stokoe	Photo’s	safety	procedures	set in	place	we	will	ensure	that	we	are	compliant	with	all	regulations	established	by	the FAA	and	look	forward	to	providing	this service	to	the	Tucson	metro	area.

Thank	you	for	your	consideration

, Stokoe	Photo	LLC Jonathan	Stokoe stokoephoto@gmail.com

520.612.8278