September 14, 2015

Trevor C. Hunter 3437 N. 900 E. North Ogden, UT 84414 (801) 391 - 9620 Trevorchunter@gmail.com U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Wa shington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (1) (2); 91.417(a)&(b ) Dear Sir or Madam: I, Trevor C. Hunter, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Trevor C. Hunter , an owner and operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Trevor C. Hunter may operate my small light -weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). I, Trevor C. Hunter, have over 15 years of commercial aviation experience . I currently hold an ATP certificate #2840011 with a First class medical . Using the DJI Phantom 3 1 , I, Trevor C. Hunter, intend to provide videography, cinematography and photography services in the areas of building inspections, real estate, site surveys, aerial mapping, special events to include but not limited to weddings, private or public parties/events, geological surveying, env ironmental studies, outdoor recreational facilities and landscapes. I, Trevor C. Hunter, am committed to safety with each flight. My, Trevor C. Hunter’s, exemption request would permit operation of a UAS(s) in areas away from the general public, airpo rts, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/photos.

1 Attachment – DJI Phantom 3 Specifications**I. Contact Information:**  Trevor C. Hunter 3437 N. 900 E. North Ogden, UT 84414 (801) 391 - 9620 Trevorchunter@gmail.com **II. The Specific Sections of Title 14 of the Code of Federal Regulations From**  **Which Trevor C. Hunter**  **Requests Exemption are:**

• 14 CFR Part 21; • 14 C.F.R. 45.23(b); • 14 CFR 61.113(a) & (b); • 14 C.F.R. 91.7(a); • 14 C.F.R. 91.9(b) (2); • 14 C.F.R. 91.103(b); • 14 C.F. R. 91.109; • 14 C.F.R. 91.119; • 14 C.F.R. 91.121; • 14 C.F.R. 91.203(a) & (b); • 14 C.F.R. 91.151(a); • 14 C.F.R. 91.405(a); • 14 CFR 407(a) (1); • 14 CFR 409(a) (1) & (a) (2); • 14 CFR 417(a) & (b) **III. The Extent of Relief**  **Trevor C. Hunter Seeks and the Reason He Seeks Such**  **Relief:** I, Trevor C. Hunter, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Trevor C. Hunter, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I may operate my small light weigh t unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Trevor C. Hunter’s, light -weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my light -weight UAS is expressly contemplated by the Reform Act. The Re form Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's, whether the UAS will be operated near airports o r heavily populated areas; and, whether the UAS will be operated by line of sight 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Trevor C. Hunter. My UAS utilizes four (4) counter- rotating propellers for balance, control and stability and is equipped with a GPS and auto return safety technology. W eighing lessthan five (5) pounds (far below the maximum 55 pound limit); including camera with

gimbal. I, Trevor C. Hunter, will operate the Phantom 3 in a safe manner, using the following checklists as well as operating procedures to determine that the aircraft is physically and electronically ready for safe flight and that permission from the property own er/representative is received: **Pre -** **flight Checklist:** • Survey the property for hazards, such as trees, utility poles and other elements that might compromise the flight then make a judgment as to whether to proceed. • Check the weather for wind speed, clo ud cover and any forecast changes that might adversely affect flight safety and performance. • Examine the aircraft- looking at connections and searching for cracks and loose parts. • Determine that the electronic elements are performing correctly (receiving GPS signals along with calibration of the magnetic compass). • Determine that the barometric altimeter reflects approximately 0 feet AGL. • Following takeoff, hover at an altitude of approximately 10 feet to assure that the Home Point is solid. Then exercis e all controls to confirm their functionality, if one of the controls is not functioning, the flight will be terminated immediately. • Give right- of-way to any manned aircraft. • Stay clear of FAA controlled airspace at airports (generally a five nautical mi le radius) as well as restricted and prohibited zones. • Fly no higher than 400' and no further than 1000' from the Home Point, recognizing that the primary responsibility is to safely keep the aircraft safely within VLOS. • Stay clear of clouds and fog (500 ' vertically and 2,000' horizontally). **Post -** **flight Checklist:** • Inspect the Phantom 3 to determine its physical and electronic condition. • Examine the aircraft- looking at connections and searching for cracks and loose parts.
**IV. How**  **Trevor C. Hunter’s Request Will Benefit the Public as A**  **Whole:** Aerial videography and photography has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies and individuals, the expense of such aerial vi deography and photography is cost prohibitive. Only large companies and high - income individuals can afford to absorb such expense. Manned aircraft pose a threat to the public through potential catastrophic crashes resulting in a potential loss of life. M y, Trevor C. Hunter’s, UAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress hasalready proclaimed that it is in the public’s interest to integrate commercially flown UAS’

into the nationa l airspace system, hence the passing of the Reform Act. My, Trevor C. Hunter, light- weight UAS is battery powered and creates no emissions that can harm the environment. **V. Reasons**  **Trevor C. Hunter’s Exemption Will Not A** **dv ersely** **A ffect Safety** 

**Or How** **the Exemption Will Provide a Level of Safety**  **A t Least Equal To Existing**  **Rule:** My, Trevor C. Hunter’s, exemption will not adversely affect safety. • My UAS weighs less than 5 pounds complete with a small light - weight high definition (HD) camera. • I only ope rate my UAS below 400 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012). • I land my UAS prior to manufacturer recommended minimum level of battery power. • I pilot my UAS through remote control/FPV only by line of sight. • My UAS has GPS with a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost. • I only operate in reasonably safe environments that are strictly controlled. • I conduct extensive pre -flight inspections and protocol, during which safety carries primary importance. • I always obtain all necessary permissions prior to operation. **VI. A**  **Summary the FAA M**  **ay Publish in the Federal Register:**  A. 14 C.F.R. § 21, 14 C.F.R. § 9 1 and 91.151: Airworthiness Certificates, Manuals and the Like 14 C.F.R. § 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a) (1). The size, weight and enclosed operational area of my, Trevor C. Hunter’s, UAS p ermits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports an d dense populations. My, Trevor C. Hunter’s, current and projected UAS’ meet or exceed each of the elements. 14 C.F.R. § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in t he form contemplated by the FARs, this Regulation is inapplicable.14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there

are no on board pilots or passengers, and given the size of the UAS, this Regulation is inapplicable . An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565 B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.151(a) with the condition that the PIC does 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. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and regis trations by me, Trevor C. Hunter . B. 14 C.F.R. § 91.119: Minimum Safe Altitudes 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will ne ver operate at an altitude greater than 400 AGL; safely below the standard of 400 AGL. I, Trevor C. Hunter , will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relatio n to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. C. 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417 (a) & (b): Maintenance Inspections The above - cited Regulations require, amongst other things, aircraft owners and operators to have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have di screpancies repaired as prescribed in part 43 of this chapter. These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Trevor C. Hunter’s, UAS. However, as a safety precaution, I, Trevor C. Hunt er, inspect my UAS before and after each flight.A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14

C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, set s forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permit exemption from Part 21 because my, Trevor C. Hunter’s, UAS meets an equivalent l evel of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permi t the FAA to exempt UAS’ from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. § 91 .7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS’, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in E xemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. **In summary ,**  **Trev or C.**  **Hunter seeks an exemption from the following**  **Regulations:** 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b) (2); 14 C.F.R. § 91.103 (b); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C .F.R. § 91.151(a); 14 C.F.R. § 91.203 (a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a) (1); and, 14 C.F.R. § 91.417 (a) & (b) I, Trevor C. Hunter, am requesting this exemption for the purposes of aerial photography, cinematography, videography, inspections and other flight operations. The reason for such a general and broad based request is that I, Trevor C. Hunter, wish to utilize a business strategy that capitalizes on opportunities a s they may arise in the future. My, Trevor C. Hunter, business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business o r hobby. Granting my, Trevor C. Hunter’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. There are no personnel on board my, Trevor C. Hunter’s, UAS and therefore the likelihood of death or ser ious bodily injury is significantly diminished. My, Trevor C. Hunter’s, operation of my UAS,weighing less than 5 pounds and travelling at lower speeds within limited areas will

provide an equivalent level of safety as that achieved under current FARs. Acc ordingly I, Trevor C. Hunter, respectfully request that the FAA grant my exemption. Respectfully submitted, Trevor C. Hunter 3437 N. 900 E. North Ogden, UT 84414 (801) 391 - 9620 Trevorchunter@gmail.co m Attachment: DJI Phantom 3 Specifications DJI PHANTOM 3 TECHNICAL SPECIFICATIONS D JI only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real - time altitude and location information to the PIC via the linked monitor (smart phone/t ablet devices) 2.1 DJI Phantom 3 2.1.1 Aircraft 2.1.1.1 Supported Battery – DJI 6000mAh LiPo 2S 2.1.1.2 We ight (Battery & Propellers Included) – 1280 g 2.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 10cm; Horizontal: 1m 2.1.1.4 Max Ascent Speed – 5m /s 2.1.1.5 Max Descent Speed – 3m/s 2.1.1.6 Max Flight Speed – 16m/s (ATTI mode, no wind) 2.1.2 Gimbal 2.1.2.1 Controllable Range – Pitch: - 90 + 30 2.1.2.2 Stabilization – 3 - zxis (pitch, roll, yaw) 2.1.3 Camera 2.1.3.1 Sensor – Sony EXMOR 2.1.3.2 Sen sor Size – 1/2.3” 2.1.3.3 Effective Pixels – 12.4M 2.1.3.4 Video Recording Mode – 4096x2160p, 3840x2160p, 1920x1080p, 1280x720p 2.1.4 Remote Controller 2.1.4.1 Operating Frequency – 2.400GHz – 1.483GHz 2.1.4.2 Max Distance – 2000m 2.1.4.3 Receiver Sensit ivity (1%PER) - 101dBm+/- 2dBm 2.1.4.4 Transmitter Power (EIRP) – FCC: 20dBm, CE: 16dBm 2.1.4.5 Wo rking Voltage – 12A@7.4V