Snap 180 Media LLC

Attn: Christopher E. Hibben 1925 Jackson Street Oshk osh, WI 54901 U.S. Department of T ra nsportation Dock et Management System 1200 New Jersey Ave., SE Wa shington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 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)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act ”) and 14 CFR Part 11, Chris Hibben of Sna p 180 Media LLC, operator of an U nmanned Aircr aft System (UAS), hereby applies for an e xemption 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 co nditions outlined herein or as may be established by the F AA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camer a(s) and sensors, would operate in the following manner: Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other relate d professional activities. Aerial video and/or photogr aph y for public and/or private use including television, public events, cinematogr aph y and news g athering. Aerial inspection/photogr aphy of residential/commercial structures under contr act with the owners or local government authority

. Aerial inspection/photogr aphy of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has reque sted it by contr act or donation. The ability to off er training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhanc e the safety of the National Airspace System (NAS) as wellas for the protection of the persons and property

.

As described fully below , the requested exemption would permit the operation of a U AS under controlled conditions in the NAS that would be a) limi ted b) controlled c) predetermined and d) will pr ovide safety enhancements to the already safe operations in the industry presently using conventional aircr aft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of T ransport ation’ s (the FAA Administrator ’s ) responsibilities to “....es tablish requirements fo r the safe operation of such aircr aft s ystems in the national airspace s ystem. ” The name and address of the applicant is: Snap 180 Media, LLC Attn: Christopher Hibben, Director of Operations/Chief Pilot Ph: 870

- 834

- 2655 Email: ps ychoticsarchery@gmail.com Address: 226 Needmore Rd Sidney , AR 72577 Regulations from which the exemption is requested:
14 CFR P art 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 9 1.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)
Snap 180 Media, LLC will operate the DJ I Inspire 1, Model T600, with a total weight of 2935g or 6.4 7lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85inch. U nder still air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. Th e DJI Inspire 1 has the ability to hover and move along a vertical and horiz ontal plane simultaneously . The DJI Inspire 1 has f our motors, Motor Model DJI 3510, powered by a 6

- cell 4500mAh or 5700mAh Lithium Polymer battery . There are four propellers, Pr opeller Model DJI 1345, in use. The DJI Inspire 1 will be controlle d with the C1 remote controller with an oper ating frequency of 2.400GHz

– 2.483GHz. The live video f eed will have an operating frequency of 5.728GHz

– 5.850GHz. The applicant will operat e the UAS in line of sight within a closed off and predetermined area owne d and/operated by the property representative.Given the small size of the U AS and the controlled environment provided the proposed operations

will adhere to the Ref orm Act ’s safety requirements. The approv al of this application presents no national security issues. Reg arding the level of safety surrounding the proposed operations and the public benefit, re duction in environmental impacts, including but not limited to reduced emissi ons and noise, the gr ant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA gr ant the requested exemption with minimum dela y. **AIRCRAFT AND EQUIV**

**ALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of saf ety because operations will further enhance the safety of the persons and/or property using conventional aircr aft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial oper ations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: The U AS will weigh less than 55 lbs. The U AS will have a maximum operating speed of no more than 50mph. Flights will be operated within line of sight of t he Pilot in Command (PIC) and/or V isual Observer (VO). Maximum flight time f or each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. Flights will be operate d a t an altitude of no more than 400 f eet Above Ground Level (AGL) and not more than 200 f eet above an elevated platform from which filming is planned. Minimum crew for each operation will consist of the UAS Pilot, the V isual Observer (VO) and may include but not limited to a Camera Operator

. The U AS pilot will be a designate d Pilot in Command (PIC) and hold a Commercial Pilot ’s License along with a Second or higher Class Me dical Certificate. If the PIC f eels another operator to be qualifie d with the neces sary skills to be PIC & possess a Commercial Pilot ’s License along with a Second or higher Class Medical Certificate, that person may be designated PIC pr ovide d they have a minimum of 20 hours of flight time with the UAS. A briefing will be perf orme d regar ding the planne d U AS operations prior to each da y’ s flight consisting of all the days’ production activities. All flights will occur under V isual Flight Rules Meteorological Conditions (VMC) only

. The flights will occur no closer than a 5 mile radius of th e geographic center/Airport Reference Po int (ARP) of a tower controlled or uncontrolled airport. If operations will be within a 5 mile radius of the geogr aphic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respectiv e airports will be contactedadvising them of the estimated flight time, flight duration, elevation of flight and other pertinent inf ormation. The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District O ffice (FSDO) no more than 72 hours but no less than 48 hours from planned operation. The operator will obtain verbal/written consent of all persons involved with the planned oper ation and ensure that only co nsenting persons will be allowed within 100 f eet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. W ith the adv ance d permission of the FSDO, operations at c loser r ange may be approved. The PIC and VO will have been tr ained in operation of U AS and receive up

- to
- date information for the particular U AS to be operated. The PIC and VO will be able to communicate by voice, radio, and/or text at all times.
Written a nd/or verbal permission and permits will be obtaine d from territorial, state, county or city jurisdictions, including law enf orcement, fire or other appropriate governmental agencies. If the U AS loses communications with the remote controller or loses GPS signal, the U AS will have the c apability to return to a pre

- determine d location within a designated location and land aut onomously

. The U AS will have the capability to abort a flight in case of unpredicted obstacles, weather , or emergencies. **14 C.F .R. P**  **art 21, Subpart H: Airworthiness Certificates 14 C.F**  **.R. §91.203 (a) (1)** Subpart H, entitle d Airworthiness Certificates, establishes the procedur al requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the siz e and limite d oper ating area associated with the aircr aft to be utiliz ed by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equiv alent level of safety under P art 11 and Section 333 of the Reform Act. The Federal Aviation Act ( 49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to ex empt aircr aft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and pop ulated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer , tha n a conventional aircr aft (fix ed wing or rotorcr aft) operating with an airworthiness certificate without the restrictions and conditions pr opose d. The U AS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger

, c arries no e xplosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. U nlik e other civil aircr aft, operations under this e xemption will betightly controlled and monitored by both the operator and under the requirements and in compliance

with local public saf ety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly

, application of these same criteria demonstrates that there is no credible threat to national security posed by the U AS, due to its size, speed of oper ation, location of ope ration, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
**14 C.F .R. § 45.23 (b). Marking of the Aircr**  **aft** The regulation requires: When marks include only the Roman capital letter "N" and the regis tr ation number is displa yed on limited, restricted or light

- sport category aircr aft or experimental or provisionally certificated aircr aft, the operator must also display on that aircr aft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "e xperimental," or "provisional," as applicable. Even though the UAS will have no ai rworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be place d. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experime ntal” will be place d on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS mark ed on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the U AS will see the i dentification of the U AS as “Experimental. ”
**14 C.F .R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.**  Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircr aft that is carrying passengers or property for compensation or hire. Snap 180 Media LLC may achieve an equiv alent level of safety as achieved by current Regulations because the applicant ’s U AS do not carry any pilots or passengers nor property

. The risks attendant to the oper ation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the U AS will have a Private Pilot ’s Lic ense along with a current Third Class or higher Me dical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I f eel the oper ation and limitations set f orth in the FOM will equate to the saf e operation of the UAS.
**14 C.F .R. §91.7(a): Civil Aircr**  **aft Airworthiness.** The regulation requires that no pe rson may oper ate a civil aircr aft unless it is in airworthy condition. As there will be no airworthiness certificate issue d for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the s ize of the aircr aft for maintenance and use of saf ety check lists prior to each flight an equivalent level of safety will be pr ovide d.
**14 C.F .R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircr**  **aft.**Section 91.9 (b) (2) provides: No person ma y op erate a U.S.

- registered civil aircr aft ... (2) For which an

Airplane or Rotorcr aft Flight Manual is not require d by §21.5 of this chapter , unless there is available in the aircr aft a current approved airplane or R ot orcr aft Flight Manual, approved manual ma terial, markings, and placards, or any combination thereof. The U AS, given its size and configuration has no ability or place to carry such a flight manual on the aircr aft, not only because there is no pilot on board, but because there is no room or capac ity to carry such an item on the aircr aft. The equivalent level of safety will be maintained by k eeping the flight manual at the ground control point where the pilot flying the U AS will have immediate access to it.
**14 C.F .R. § 91.103: Preflight Action.** 
T his regulation requires each pilot in command to tak e certain actions before flight to insure the safety of flight. As FAA approved rotorcr aft flight manuals will not be provided f or the aircr aft an exemption will be nee ded. The PIC will tak e all actions a s stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather , flight battery requirements, landing and tak eoff distances and aircr aft performance data before initiation of flight.
**14 C.F .R. §91.109: Flight Instru**  **ction.** Section 91.103 provides that no person ma y operate a civil aircr aft (except a manned free balloon) tha t is being used f or flight instruction unless that aircr aft has fully functioning dual controls. UAS and remotely pilote d aircr aft, by their desig n do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via r adio communications. The FAA has approved exemptions for flight training without fully functional dual co ntrols for a number of aircraft and for flight instruction in experimental aircr aft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircr aft and by the size and speed of the aircr aft.
**14 C.F .R. §91.119: Minimum Safe Altitudes.**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complie s with an y route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planne d, an e xemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exc eeds 400 feet AGL, the UAS will not be operated more than 200 f eet above the highest point on the s tructure. It will however be operated in a restricted area with security perimeter , where buildings and people will not be expose d t o operations without t heir pre

- obtaine d c onsent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be tak en without the permission of the property owner or local officials. Beca use of the adv ance notice to the property owner and participants in the filming activity , all aff ected individuals will be aware of the planned flight operations. Compared to flight oper ations with aircr aft or rotorcr aft weighting f ar more than the maximum 55lbs. proposed hereinand the lack of flammable fuel, any risk associated with these operations is f ar less than those

presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

altitude operations of the UAS will ensure separation between these UAS operations and the oper ations of conventional aircr aft that must comply with Section 91.119.
**14 C.F .R. §91.121 Altimeter Settings.**  This regulation requires each person operating an aircr aft to maintain cruising altitud e by reference to an altimeter that is set “

... to the elevation of the departure airport or an appropriate altimeter setting av ailable before departure. ” As the U AS may not have a barometric altimeter , but instead a GPS altitude read out, an e xe mption may be neede d. An equivalent level of safety will be achieved by the operator

, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator be fo re flight.
**14 C.F .R. § 91.151(**  **a): Fuel Requirements for Flight in VFR Conditions** Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first p oint of intended landing, and, assuming normal cruising speed

– (1) During the day , t o fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. ” The battery powering the UAS provides appro ximately 30 minutes of p owered flight. T o meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’ s proposed flight area and the location of its pr opose d operations within a pre determined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an ex emption from 14 CFR §91.151(a) f alls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and sp eed of the small UAS. Additionally , limiting U AS flights to 10 minutes would greatly reduce the utility for which the e xemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planne d landing zone from anywhere in its limited operating area.
**14 C.F .R. §91.203 (a) and (b): Carrying Civil Aircr**  **aft Certification and Reg istration**  The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircr aft unless it has within it the fo llowing: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragr aph(a) of this section or a special flight authorization issue d under §91.715 is displa yed at the cabin or

cockpit entrance so that it is legible to passenge rs or crew . The U AS fully loade d weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and regis tration documents or to display them on the UAS. An equiv alent level of safety wi ll be achieved by k eeping these documents at the ground control point where the pilot flying the U AS will have immediate access to them, to the extent they are applicable to the U AS. **14 C.F .R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenan**  **ce Inspections.** These regulations require that an aircr aft operator or owner “shall have that aircr aft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragr aph (c) of this section, have disc repancies repaired as prescribed in part 43 of this chapter..., ” and others shall inspect or maintain the aircr aft in compliance with Part 43. Given that these section and Part 43 apply only to aircr aft with an airworthiness certificate, these sections wi ll not apply to the applicant. Maintenance will be accomplished by the oper ator pursuant to the flight manual and operating handbook. An equivalent level of saf ety will be achieved because the U AS is very limited in siz e and will carry a small payload and oper ate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 f eet AGL. The operator will ensure that the UAS is in working order prior to initiating fli ght, perform required maintenance, and k eep a log of an y maintenance performed. Moreover

, the operator is the person most f amiliar with the aircr aft and best suited to maintain the aircr aft in an airworthy condition to provide the equivalent level of safet y. An equiv alent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's U ser Manual. As provided in the FOM, the oper ator will ensure that the UAS is in working order prior to init iating flight and perf orm required maintenance nee ded. **Additional Information** The applicant, Christopher E. Hibben , has been involved in the building and piloting of remote controlled aircr aft for more than 5 years and has been a Private Pilot for more tha n 7 years with over 500 hours of PIC in multiple aircr aft. Also the primary pilot, Christopher E Hibben , has an indepth understanding of the capabilities and safety concerns inv olved in using this technology as an asset to the community . Satisfaction of cr iteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the gr ant of the requested exemptions allowing the commercial oper ation of the applicant ’s UAS. Sincerely , 

### Christopher E. Hibben