**October 16**  **, 2015**

**U.S. Department of Transportation** Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590 **Petitoner:** Henry Cummings Cummings Photography, LLC 21 Jaytee Court Havana, Fla. 32333 **RE:** I **Henry Cummings ,**  **petitioner and ow**  **ner of Cummings Photography**  **, LLC r**  **equest fo**  **r exemption from multiple regulatory provisions to allow the use of small**  **, u**  **nmanned aerial systems (** **UAS )**  **.** Dear Sir or Madam:
I Henry Cummings petitioner and o wner of Cummings Photography , LLC respe ctfully request an exemption from several provisions of Title 14 of the Code of Federal Regulations (CFR PART ) to permit the use of small , unmanned aerial systems (UAS ) for the purposes of photography and videography. The use of such systems would provide much safer alternatives to fixed or rotary wing craft as well as being much safer than other methods of collecting photographic and video graphic data. Petitioner seeks the requested exemptions to permit p etitioner to offer commercial small UAS services for a variety of industries and applications, including:

 Aerial Mapping
 Aerial Advertising
 Aerial Surveying
 Forest and Wildlife Conservation
 Agricultural operations
 Event Photography and Videography (i.e. weddings, parties, recreational activities)


###  P atrolling (pipelines, power lines, towers, roofs, buildings and canals); **Regulatory Basis for Request** This request is in accordance with Section 333 of the FAA Modernization and Reform Act of 2012 . Through which Congress acknowledged the use of such systems prior to the finalization of specific small UAS rules and regulations. Until such time as these regulations are finalized, the Secretary of Transportation is required to make a determination whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS). As part of such determination the Secretary is to consider the following:

- The small UAS ’s size, weight, speed, and operational capability;

- Operation of the small UAS in close proximity to airports and populated areas; and

- Operation of the small UAS within visual line of sight of the operator.**Background**

Cummings Photography , LLC is a start
-up company offering small unmanned aircraft system (UAS) services. The objective is to provide safe, reliable, cost effective services to customers in the North Florida and South Georgia

. Cummings Photography , LLC is located in Havana , Florida. In addition to being the owner and operator, I will also be the pilot in control (PIC). I previously held a technical class amateur radio license and have hands on experience building a remote controlled robot (battle bot) for competitive entertainment purposes. I have more than 30 years of experience building and supporting automated business systems for the State of Florida and possess valuable experience setting, documenting and following best practices , procedures and protocols to ensure safe and reliable results from technology implementations

. I have been using remote control led equipment for more than 30 years and would like to leverage my collective experience to provide safe, economical and environmentally friendly aerial drone photography and videography services in the North Florida and South Georgia geographical area. **Name and Address of Petitioner Henry**  **Cummings (** **PIC )**  Cummings Photography , LLC 21 Jaytee Court Havana, Fla. 32333 Email: Cummings HL @comcast.net (preferred method of contact) Phone: (850) 933

- 7152 **DJI Phantom 3 small Unmanned Aircraft System**  **(UAS)** Th e small UAS of choice for providing photography and videography services are the DJI Phantom 3. Th e small UAS is equipped with safety features that will allow the aircraft to return home , if the signal is lost or return home with the press of a button. The aircraft has an electronic limiter to prevent the aircraft from exceeding 35 miles per hour. The controller operates at 2.4 GHz. The aircraft is equipped with a camera for taking photos and video footage. It also has the ability to hoover in place if the controlling si gnal is lost prior to initiating the “Return Home” safety feature. The aircraft is equipped with optical sensors to allow for indoor flying. Detailed information regarding fail safe features, operating conditions and other specifications can the reviewed in the attached manual s . DJIPhantom 3

– All manufacturer recommendations will be followed. See Attached Manuals:
 DJIPhantom 3 Pilot Training Guide
 DJIPhantom 3 User Manual
 DJIPhantom 3 Professional User Manual (Too large

– link to download below) http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf
 DJIPhantom 3 Intelligent Flight Battery Safety Guidelines
 DJIPhantom 3 Safety Guidelines**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY**

The petitioner proposes that the exemption requested herein apply to civil aircraft that have the c haracteristics that operate with the limitations listed herein

. These limitations provide for an exceptional level of safety for all flight operations. These limitations and conditions to which I, Henry Cummings agrees to be bound when conducting commercial operations under an FAA issued exemption include :

 DJI Phantom 3 small UAS is designed to hover in place via GPS and operate in less than a 13 knot (15 mph) wind. For safety and flight stability, I will not fly in winds exceeding 13 knot (15 mph).
 The DJI Phantom 3 has a “Beginner Mode” which will limit altitude during training exercises
 The DJI Phantom 3 has built in safety systems include a GPS mode that allows my small UAS to hover in place when radio controls are released.
 The DJI Phantom 3 has GPS a flight safety feature whereby it hovers and then slowly Lands if communication with the remote control pilot is lost;
 I will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;
 With three programmable flights modes to choose from, I will utilize the P

- mode which provides optimum stability and landing characteristics by leveraging GPS and Vision Positioning using optical sensors . This is the safest, most reliable and stable mode to prevent accident and hazard.
 When pilot communication is lost for an extended amount of time the small UAS is designed to slowly descend and return to the point of take

- off.
 No fli ght operations shall take place near airports, Hospitals nor Police heliports.
 DJIPhantom 3 is capable of vertical and horizontal operations, and will be flown within the visual line of sight (VL OS ) of my location.
 Utilizing battery power rather than com bustible fuels, flights will generally last less than twenty ( 2 0), with an altitude under three hundred ( 200 ) feet
 DJI Phantom 3 small UAS weighs approximately 2.8 lbs. complete with gimbal and high resolution camera system including battery system;
 DJIPhantom 3 only operates for 10

- 20 minutes per flight;
 I will land the DJI Phantom 3 prior to manufacturer recommended minimum level of battery power;  I will keep the small UAS within visual line of site (VLOS) at all times.
 I will require the visual observer (VO) to keep the small UAS within visual line of site at all times.
 I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach the area where the small UAS is performing flight operations

.  I will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;
 I will operate the small UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);
 I will operate the small UAS in reasonably safe environment that is strictly controlled, away from power lines (unless the purpose of flight is to investigate the power lines) , elevated lights, airports and actively populated areas;  I will conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance; I will always obtain all necessary permissions prior to operati on; and, will have procedures in

place to abort flights in the event of safety breaches or potential danger. 

###  I will operate outside of 5 nautical miles of an airport reference point, as denoted on a published aeronautical chart, unless written permission i s first obtained from any applicable airports, and the airport files a NOTAM describing flight duration and area of operation.
 I do not intend to conduct flight operations in areas that have existing requirement to notify the FSDO but will comply by doing so it the situation occurs

. **PIC Qualifications and Responsibilities** Henry Cummings (PIC) will have accum ulated and logged a minimum of 20 hours of total logged time with the DJI Phantom 3 prior to performing commercial flights

. The visual observer (VO) must be able to maintain visual line of sight with no assistance beyond corrective lenses. It is the responsibility of the PI C to make the determination for a qualified VO and to be aware of VO limitations. Moreover, the VO will not be operating the small UAS

. The small UAS will not be operated within 5 nautical miles of an airport and will not be flown at altitude which exceeds 2 00 ft. The small UAS shall not operate at speeds exceeding 35 miles per hour. **Granting an Exemption is in the Public Interest**  In regards to specific requests the FAA has adopted requirements, providing that applicants of such requests shall explain why granting the exemption would not adversely affect safety or how the exemption would provide at least an eq uivalent level of safety compliance with the underlying regulation. In this case, approval of this exemption would advance the public interest by significantly enhancing the safety of persons performing high risk activities like walking on building tops to assess structural integrity, viewing undeveloped land features in areas that may contain dangerous animals, walking on roof tops that may be slippery and resulting injury or fatality , entering hazardous areas to locate lost people o r animals, or climbing high risk structures to perform visual inspections . Other reasons for public interest is to greatly improve efficiencies for performing agricultural studies, improve d real estate sales by providing better views, promotion of healthier living by capturing breath taking views of hiking trails and kayak adventures to encourage active lifestyles

. Further reasons include reductions in noise pollution caused by large winged aircraft and the reduction in emissions caused by biofuels. The safety, environmental, financial, agricultural and improved efficiencies are just a few of the unlimited reasons granting this exemption is in the public interest. As described more fully below, the requested exemption would permit the operation of small UAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety, both the public and the worker. By using a small UAS for such operations, a higher level of safety can be achieved for three primary reasons: F irst, the potential loss of life is diminished because a small UAS carries no person onboard and

will only be operated in specific areas, away from mass populations.
 Second, there is no fuel on

-board a small UAS , and thus the potential for fire or explosion is greatly diminished.
 Third, the small size and extreme maneuverability allows for greater control on the behalf of the pilot in order to avoid and move away from hazards quickly and safely.
 High risks activities associated with collecting imagery data such as climbing, rope propelling, walking on possible compromised surfaces or flying in manned aircraft will be reduce d and often eliminated. In addition, approval of this exemption would greatly reduce air traffic, air craft noise, save aircraft fuel and potential loss of life. **Provisions for which an exemption is sought** 14 CFR Part 21 14 CFR Part 6 1 14 C.F.R. 91.10 3 14 C.F.R. 91.10 5 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 ( a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b ) **Explanation: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 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 exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular small UAS . In all cases, an analysis of these criteria demonstrates that the small UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) opera ting with an airworthiness certificate without the restrictions and conditions proposed. The small UAS to be operated is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, does not c arry explosive materials or flammable liquid fuels, and operates exclusively within a secured area ass et out in the manufacturer’s manual s . Unlike other civil aircraft, operations under this exemption will be

tightly controlled and monitored by both the operator and a visual observer , pursuant to the user’s manual requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation

. The application of the same criteria demonstrates that there is no credible threat to national se curity posed by the small UAS , due to its size, speed of operation, location of operation, 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 Aircraft & 14 C.F.**  **R. Part 47. Aircraft Registration** These regulations require: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near 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," "experimental," or " provisional," as applicable. Due to the size of the small UAS, it is not possible to comply with the registration number size regulation. An exemption is requested. Cummings Photography , LLC will register the small UAS under the appropriate serial number in accordance with the referenced regulation. Cummings Photography , LLC will mark the fuselage with a Registration Number as large as practicable in locations on the small UAS as feasible. **14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.**  Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the small UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent l evel of safety of current operations by requiring the pilot in control of operating the aircraft to consistently follow the steps in a pre

- flight checklist and to use small UAS that have inherent features to ensure the small UAS either return to home upon loss of signal or land itself safely upon signal loss or other failure. Unlike a conventional aircraft that carries the pilot and passengers, the s mall UAS is remotely controlled with no living thing on board. The area of operation is controlled and rest ricted, and all flights are planned and coordinated in advance. The level of safety provided by the requirements included in the manufacturer’s manual s exceed that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. All flights will have PIC and VO. The risks associated with the operation of the small UAS are so diminished from the level of risk ass ociated with commercial operations contemplated by Part 61 when drafted, that allowing operations and granting of this exemption of the small UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). **14 C.F.R. Part 61, additional subparts** When the FAA introduces small UAS specific regulations (such as 14 C.F.R. 107), Cummings Photography , LLC will transition to the appropriate licensure at that time

.**14 C.F.R. §91.7(a): Civil aircraft airworthiness.**

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be gra nted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the manual for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.** Section 91.9 (b) (2) provides: No person may operate a U.S.

-registered civil aircraft

. (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 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. The small UAS , given its size and configuration does not have the ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the operations procedures manual and all manufacturer manual s at the ground control point where the pilot flying the small UAS will have immediate access to appropriate manuals.
**14 C.F.R. § 91.103: Preflight action** This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. Cummings Photography , LLC can provide an equivalent level of safety as set forth in small UAS user manual. The P ilot in Control in the presence of the visual observer will perform pre

- flight checks including reviewing weather conditions , flight battery requirements, controller battery levels, UAS battery level, landing and takeoff distances , identification of potential hazards and flight path assessment prior to initiation of flight. All non

- essential flight personnel will be asked to leave the small UAS operational area and will be informed of the presence of UAS flight in progress. Both pilot in control (PIC) and visual observer (VO) will maintain visual line of sight at all times. For additional safety in maintaining line of sight, the small UAS is equipped with a return to home feature. Flight Environment Requirements to be followed according to small UAS manufacturer :1. Do not use the aircraft in severe weather conditions. These include wind speed exceeding category 4, snow, rain and smog. 2. Fly in open fields as high buildings or steel structures may affect the accuracy of the onboard compass. 3. Keep the DJ I Phantom 3 away fro m obstacles, crowds, high voltage power lines, trees or bodies of water when in flight. 4. Reduce the chance of electromagnetic interference by not flying in areas with high levels of electro magnetism, including base stations or radio transmission towers. 5. The DJ I Phantom 3 cannot operate within the polar areas. 6. Do no fly the aircraft within no

- fly zones specified by local laws and regulations. The following pre

- flight check list from the safety user manual will be initiated prior to all flights: 1. Remote Controller, smart batter, Range Extender and smartphone are fully charged. 2. Propellers are mounted correctly. 3. Gimbal clamp has been removed. 4. Damping absorbers are in good condition, not broken or worn. 5. Anti

- drop kits have been mounted correctly. 6. Camera lens cap has been removed 7. Micro

- S D card has been inserted in necessary. 8. Gimbal is functioning as normal. 9. Motors can start and are functioning as normal. 10. DJ I VI SION App can connect to the camera.
**14 C.F.R. §91.109: Flight instruction:** Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Small UAS s and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight c ontrol is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Cummings Photography , LLC will ensure flight instruction to be in accordance with the manufacturer’s guidelines and by utilizing the Phantom 3’s ‘Beginner Mode’ function to train in the nuanced flight of the small UAS

. Routine flight exercises will be performed monthly according to the training exercises which are detailed in the Phantom 3 Pilot Training Guide. **14 C.F.R. §91.119: Minimum safe altitudes** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) allows aircraft to be operated at less than the minimums prescrib ed. As this exemption is for a small UAS , the exemption requests authority to operate at altitudes up to 2 00 AGL an exemption may be needed to allow such operati ons. As set forth herein, except for the limited conditions stated in the user manual, the small UAS will never operate at higher than 200 AGL.Itwill however typically be operated in a restricted area, where buildings and people will not be exposed

to operations without their pre

- obtained consent. 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 taken without the permission of the property owner or lo cal officials. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is less likely than those associated with conventi onal aircraft. In addition, the low

- altitude operations of the small UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119. Cummings Photography , LLC also notes that the proposed operations covered under this exemption request are intended to be conducted with minimum safe altitudes for the purposes of inspection s, monitoring, collecting data and advertising . The operation of a small UAS close to large structures would provide a negligible flight hazard when compared to other conventional aircraft. **14 C.F.R. §91.121 Altimeter Settings** In pertinent part, this section requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set to “...the elevation of the departure airport or an appropriate altimeter setting available before departure.” As Petitioner’s small UAS may not have a barometric altimeter, it does have GPS altitude readout, an exemption may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator, and prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PI C. The PIC will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of altitude. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** Section 91.151 (a) prohibits an individual from beginning “a fl ight 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.” Cummings Photography , LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS , in a tightly controlled area where only people and property owners or official representatives who have signed waivers or granted permission will be allowed, with less than 25 minutes of reserve fuel (battery) , does not realize the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. **14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration** The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate.(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of

this section 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. The small UAS fully loaded 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 registration documents or to display them on the small UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the small UAS for immediate access to them, to the extent they are applicable to the small UAS . The FAA has issued numerous exemptions to this regulation. **14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenanc e Inspections**  These regulations require that an aircraft operator or owner “shall have that 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 discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections should not apply to Cummings Photography , LLC small UAS . Maintenance will be accomplished by the operator according to the manufacturer’s recommendations . An equivalent level of safety will be achieved because these small UAS s are very limited in size and wil l carry a small camera and operate only in restricted areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be operating from no higher than 2 00 feet AGL. As provided in the user and safety manual, the operator will ensure that the small UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed as well as logging all flight time

. Moreover, the operator is the person most famil iar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. **Regulatory Relief from Other Sections as deemed appropriate by** FAA Cummings Photography , LLC requests additional relief, to the extent practic al, from provisions which the FAA has learned through the rulemaking process have pro ven impractical for the use of small UAS s. **EXHIBIT A** 

**– FEDERAL REGISTER PUBLICATION VERBIAGE**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: **Applicant seeks an exemption from the following rules** : 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned aircraft system (UAS) which is 55lbs or less for the purposes of Aerial Mapping , Aerial Advertising Aerial Surveying ,Forest and Wildlife Conservation , Agricultural operations , Event Photography and Videography (i.e.

weddings, parties, recreational activities) and p atrolling\inspecting (pipelines, power lines, towers, roofs, buildings and canals); Conventional inspections require fixed wing aircraft, rotary winged aircraft or qualified climbers to work on or around electrical and other hazards. In contrast, a UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board as well as limiting risk to Cummings Photography , LLC . The small UAS is transported or carried to the location and not flown. The small UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of a small UAS , weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. The chosen small UAS (DJI Phantom 3) is a lightweight aircraft that will operate at slow speeds (no more than 35 mph) , close to the ground in a controlled environment and, as a result, is far safer than conventional operations conducted with manned aircraft operating in close proximity to the ground and people Cummings Photography , LLC is committed to safe operation and due to the foregoing reasons should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. Upon receiving our 333 exemption Cummings Photography , LLC plans to immediately apply for Certificate of Waiver or Authorization (COA)

. In summary, reduction of local area air traffic and the reduction of noise pollution resulting from manned aircraft. The regulation and management of drone professionals for commercial purposes would assist in providing citizens and businesses with valuable low risk options for services best matched for small UAS s. The safety, economical environmental, humanitarian and agricultural us e of drones pi loted by qualified professional s, justifies the approval of this exemption request
. Thanks, Henry Cummings Cummings Photography , LLC 21 Jaytee Court Havana, Fla. 32333 Email: CummingsHL@comcast.net (preferred contact method) Phone: 850

- 933

- 7152