JCreativeStudio, LLC. Elm Grove, Wisconsin www.jcreativestudio.com July 30, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave , SE Washington, DC 20590

JCreativeStudio, LLC’s Petition for Exemption to Operate Unmanned Aircraft Systems for Aerial Photography and Filming

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER JCreativeStudio, LLC. ATTN: John Shih 1150 Pilgrim PKWY Elm Grove, WI 53122 jshih@jcreativestudio.com Direct Phone: 206

- 915

- 6734 1150 Pilgrim PKWY Elm Grove, WI 53122 414

- 810

- 6734 photos@jcreativestudio.com7/30/15 Page 2 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com I. PETITION SUMMARY Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“ FAA”) general exemption authority under 49 U.S.C. § 44701(f), JCreativeStudio, LLC . (“Petitioner”) hereby petitions for exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91. 151, 91.203(a) and (b), 91.405(a), 91.407(a)(1 ) 91.409(a)(2), 91.417(a)

- (b). The proposed exemptions, if granted, would allow Petitioner to operate small, camera

- mounted unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of closed

set filming of motion pictures, music videos, web videos, corporate videos, television programs and commercials, wedding and entertainment venue videos, and still photography. Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s UAS operators, and the restricted, sterile environment with in which Petitioner will operate, the requested exemptions fall squarely within the zone of safety envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety achieved by replacing significantly larger manned aircraft carrying cr ew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant Petition are in the public interest. Thus, the requested exemptions should be granted.7/30/15 Page 3 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Attachments: These attachments are too large for submission via the submission portal. They are available at this website for viewing or download. http://www.dji.com/product/inspire

- 1/download 1) Inspire 1 User Manual (EN) v1.2 2015

- 05

- 14 2) Inspire 1 Quick Start Guide (EN) v1.2 2015

- 05

- 14 3) Inspire 1 Safety Guidelines v1.0 2014

- 12

- 31

II. BACKGROUND For more than 4 years, Petitioner have provided photography and cinematography services for weddings, concerts, conferences and other public and private events around the state of Wisconsin . Combining the latest photography and cinematography technology with a long track record of safe and successful projects, Petitioner’s technical expertise has been relied upon for photography and live event projects of a wide variety. In order to continue to provide the highest level of service, and to promote safety by eliminating the need for large man ned aircraft at events, Petitioner seeks regulatory exemptions that will allow Petitioner to employ camera

- mounted UAS technology in the photography and cinematography services

.

III. STATUTORY AUTHORITY
A. Section 3337/30/15 Page 4 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the National Airspace System (“NAS”). Section 333(a) states that the FAA “shall determin e if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the [comprehensive] plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Sectio n 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operational authorization.” The FAA has committed to complying with this mandate by granting several petitions almost identical to the one at hand. See, e.g., Exempt ion No. 11062, Regulatory Docket No. FAA

- 2014

- 0352 (granting regulatory exemptions to Astraeus Aerial for operation of unmanned aircraft systems for the purpose of filming for the motion picture and television industry). Section 333(b) identifies several factors that the FAA should consider in determining whether commercial UAS operations should be approved. These include UAS that, “as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation w ithin visual line of sight do not create a hazard to users of the [NAS] or the public or pose a threat to national security.” See Section 333(b). B. Section 44701(f) In addition to the specific authority conferred by Section 333, the FAA Administrator has general authority to grant exemptions from the FAA’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See U.S.C. § 44701(f).7/30/15 Page 5 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com IV. REQUESTED EXEMPTIONS Petitioner requests relief fr om the following regulations: Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. Section 61.113 prescribes that “ no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft,” ( see Sec tion 61.113(a)), and that “a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does n ot carry passengers or property for compensation or hire,” ( see Section 61.113(b)). Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, including a provision impliedly limiting to persons holding a commercial pilot certificate the ability to act as pilot in command of an aircraft “[f]or compensation or hire.” Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthy condition. Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.7/30/15 Page 6 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include, “For any flight, runway lengths at airports of intended use, and the following ta keoff and landing distance information: ... For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein.” Section 91.119( c) prescribes that, except when necessary for takeoff or land ing, no person may operate an aircraft below the following altitudes: “Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated are as. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.” Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altim eter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Section 91.151(a) prescribes that no person may begin a flight in an airplane under 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, (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. Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective7/30/15 Page 7 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com U.S. registration certificate issued to its owner or, for operatio n within the United States, the second copy of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in Part 43 of the chapter. Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under § 43.7 of the same chapt er. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this c hapter. Section 91.417(a) and (b) prescribes, in pertinent part, that

- (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventative mai ntenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the7/30/15 Page 8 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the air craft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since th e last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, th e AD or safety directive number and revisions date. If the AD or safety directive involves recurring action, the time and date when the next action is required.7/30/15 Page 9 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteratio n to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be

r etained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

V. PETITIONER’S PROPOSED OPERATIONS SATISFY SECTION 333.
A. Unmanned Aircraft System The UAS to be operated under this request are less than 55 lbs. fully loaded, will be operated at a speed of no more than 50 knots, carry neither a pilot nor passenger, carry no explosive materials or flammable liquids, and operate exclusively within a sec ured area. Petitioner’s UAS use a radio frequency spectrum for operation and control that complies with Federal Communications Commission (“FCC”) requirements, and Petitioner has integrated safety features into the UAS, as described in Inspire 1’s User Man ual, Quick Start Guide, and7/30/15 Page 10 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Safety Guidelines (collectively “ Flight Operations and Procedures Manual” also kno wn as “FOPM”)

. The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less th an 104 Ounces (2935g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 43 knots (22m/s) and a maximum climb rate of less than 1200 feet per minute (5 m/s). It is powered by four electric motors wit h a distance between motors of less than 18 inches (438mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is con trolled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), di stance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life l imits flight times to approximately 22 minutes maximum. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when th e battery reaches a predetermined low state. It is anticipated that flights will usually last less than 15 minutes. More information is available in attachment 1 or at http://www.dji.com/product/inspire

- 1

. Thus, good cause exists for granting Petitioner’s requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for flight in VFR conditions).7/30/15 Page 11 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F. R. Part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as large as practicable. Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), Petitioner seeks su ch relief because Petitioner will not have a typical barometric altimeter onboard the UAS. Instead, altitude information will be provided to the UAS PIC via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- sc reen display. The altitude information will be generated by equipment installed onboard the UAS, using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requested relief from 14 C.F.R. § 91.121. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warrant ed (if necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. Part 11 and Section 333. The UAS operated without an airworthiness certificate in the restricted environment and under the conditions and limitations proposed by Petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the proposed limitations and conditions.7/30/15 Page 12 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com Petitioner will strictly comply with safety and maintenance procedures included in all applicable UAS manufacturer’s instructions and operating manuals. To the extent such information is not included in the guidelines developed by the manufacturers, Petiti oners will develop and document maintenance, overhaul, replacement, and inspection requirements, procedures to document and maintain maintenance records with regard to Petitioner’s UAS, and UAS technician qualification criteria. Petitioner’s FOPM will inc lude maintenance requirements for Petitioner’s UAS, including “on

- condition” maintenance and modifications. In light of these mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) are warrante d.
B. UAS Pilot in Command Petitioner’s UAS pilot in command (PIC) shall have passed the FAA ground school examination but shall not be required to hold a current pilot’s license. Since there are no standards for either private or commercial UAS pilot certificates, knowledge of airspace regulations acquired from FAA ground school and dexterity in the control and operation of the UAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. According to the FAA, “the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model experience , culminating in verification through testing.” See Exemption No. 11062, Regulatory Docket No. FAA

- 2014

- 0352, at p. 18. With those factors in mind, Petitioner’s UAS PIC shall be required to meet several conditions :7/30/15 Page 13 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com • The UAS PIC will have accumulated and logged a mi nimum of five

- hours of flight time with the specific make and m odel of the UAS to be utilized for operations under the exemption and three take

- offs and landings in the preceding 90 days.

• The UAS PIC will have successfully completed the qualification process as specified in the operations manuals, to include a knowledge and skill test. 1 2 Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s understanding that Petitioner’s UAS will not require an airworthine ss certificate in accordance with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessary. To the extent such an exemption is deemed necessary, Petitioner asserts that it should be granted in light of the safety p rocedures proposed herein. In accordance with the pertinent part of 14 C.F.R. § 91.7(b), the operator in command of Petitioner’s UAS shall be responsible for determining whether the aircraft is in a safe condition for flight. Petitioner’s manuals for maint enance and operations shall include safety checklists to be used by the operator in command prior to each flight. Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight manual, marking, and placard requirements and § 91.203(a) and (b), (Civil aircraft: certifications required), it is Petitioner’s understanding that relief from these regulations is no

1 Prior to operating, the PIC will be required to pass the knowledge and airmanship test qualifications developed by Petitioner for the UAS (which will be inclu ded in Petitioner’s FOPM ). There are no established practical test standards that support a jurisdictional FAA FSDO (“Flight Standards District Office”) evaluation and approval of company designated examiners. Petitioner will conduct these tests in accorda nce with its FOPM . Given the constraints of the proposed operations, this procedure for testing will not adversely affect the safety of the NAS.7/30/15 Page 14 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com longer necessary in light of the FAA Memorandum “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014. To the extent the FAA deems an exemption from this section necessary for Petitioner’s proposed operations, such exemption should be granted in light of the mitigating fact that Petitioner will maintain the documents required under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station during flights. Additionally, 100% of Petitioner’s operations will utilize a visual observer (“VO”). The VO may be used to satisfy the VLOS require ment as long as the PIC always maintains VLOS capability. The VO and the PIC will be able to communicate verbally at all times during operational flights. Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply
with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and takeoff distances before initi ation of a flight. The PIC will also account for all relevant site

- specific conditions in their preflight procedures. Risks presented by sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and initiate a return

- to

- home sequen ce if needed. The PIC’s UAS operation will be limited to a unique and restricted environment. Given the (1) separation of private photography and filming operations from other manned operations, (2) parallel nature of aeronautical knowledge requirements incumbent in the FAA ground school exam and the process of obtaining a private pilot’s license, and (3) the proposed UAS7/30/15 Page 15 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com airmanship skills of Petitioner’s PICs, the additional manned airmanship experience of a private pilot would not correlate to the airm anship skills necessary for Petitioner’s proposed unmanned operations. Thus, Petitioner’s request for relief from 14 C.F.R. § 61.113(a) and (b) and § 61.133(a) should be granted. C. Operating Parameters of Petitioner’s UAS Operations will be performe d only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted with in and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Petitioner’s UAS operations will be conducted within a n event’s predetermined and access controlled environment . In this controlled environment, Pe titioner’s operations will remain within VLOS of the PIC and VO, below 400 feet AGL, and at speeds below 50 knots. Flights will be operated at a late ral distance of no less than 100 feet from any inhabited structures, buildings, vehicles, vessels, or nonpa rticipating persons. The UAS will operate in accordance with the safety and operational requirements of the FOPM. Prior to the operation, a Safety Risk Analysis Plan (“SRAP”) will be created which includes all safety and operational information necessary t o safely carry out the flight. When applicable, all UAS operations will be conducted7/30/15 Page 16 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com in accordance with any state or local privacy laws. Only participating persons at the event will be permitt ed within the operating area. 3 Consistent with the relief typically provided to manned operations under FAA Order 8900.1, Volume 3, Chapter 8, Section 1, Petitioner requests relief from 14 C.F.R. § 91.119(c) with respect to those participating persons, vehicles, and structures directly involved in the performance of the actual filming. Regarding distance from participating persons, the FOPM set forth safety factors for authorized and consenting production personnel. Because those procedures are specific to participating persons, no furth er FSDO or aviation safety inspector approval is necessary for reductions to the distances spec ified in Petitioner’s manuals. Regarding the distance from nonparticipating persons, Petitioner will ensure that no persons are allowed within 500 feet of the operating area except those consenting to be involved and necessary for the event , with the possibility of reducing this distanc e to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. This is consistent with FAA Order 8900.1, V3, C8, S1. Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center

o f a non

- towered airport unless a letter of agreement with that airport’s management is obtained and the operation is conducted in accordance with a Notice to Airmen (“NOTAM”). Additionally, Petitioner will not operate in Class B, C, or D airspace without w ritten approval

3 Pursuant to Order 8900.1 V3, C8, S1, “participating persons” includes all persons associated with the film ing production. Participating persons will be briefed on the potential risk of the proposed flight operations and must acknowledge and accept those risks prior to participation.7/30/15 Page 17 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com from the FAA. Nor will Petitioner operate the UAS 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. Petitioner’s UAS will remain clear and yield the ri ght of way to all manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and hangliders). Although Petitioner seeks to comply with the waiver process as described in FAA Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and Television Filming), the current section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from issuing the required Cert ificate of Waiver, because the section did not originally provide for UAS operations. Thus, Petitioner seeks exemption from the applicable regulations normally waived during that process. Petitioner proposes that the FAA include the required notifications and coordination with jurisdictional FSDOs through the conditions and limitations accompanying the requested exemption, and that the exemption sought herein will take the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 890 0.1. Under this rubric, Petitioner will notify every FSDO with jurisdiction over the area that Petitioner plans to operate, just as with manned filming operations, and those FSDOs will have the ability to coordinate further conditions and limitations with the UAS Integration Office to address any local concerns. Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations under this grant of exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation.7/30/15 Page 18 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com D. The Requested Exemption Promotes the Public Interest The enhanced safety achieved by replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS ope rations enabled by the instant Petition are in the public interest. Moreover, as the FAA has already recognized, “UAS provide an additional tool for the wedding and event industry, adding a greater degree of flexibility, which supplements the current capab ilities offered by manned aircraft.” See Exemption No. 11062, Regulatory Docke t No.
FAA

- 2014

- 0352, at p. 22. Operations for this petition will enable our business to create calming, relaxing films for hospital, clinics and other facilities in line with our current ground based projects. Additionally, this petition will allow our business to provide service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subject s that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pestic ides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients wit h photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Valid liability insurance has been in effect . Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in7/30/15 Page 19 of 19

JCreativeStudio, LLC. Elm Grove, Wi sconsin www.jcreativestudio.com collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Repo rts, or other means as required.

V. CONCLUSION For the foregoing reasons, the regulatory exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations for the purposes of “aerial photography, cinematography , videography, mapping, crop surveying, inspections and other flight operations ”. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance.

Respectfully submitted, JCreativeStudio, LLC.
By 

# John Shih

John Shih Owner JCreativeStudio, LLC.