**July 28, 2015**  Wi lliam Paul Richard, Director’s Chair Production, LLC 5239 Pembroke Way, San Ramon, CA 94582, 510

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- 0655, dcpbayarea@gmail.com www.directorschairproductions.com Federal Aviation Administration: I, Wi lliam Richard of Director’s Chair Productions, LLC , the petitioner, 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 as an experienced operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations ( “FARs”) listed below so that I may operate an unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulation s & Policies. This is a formal request for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.15 1(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b). The petitioner intend s to operate DJI’s following UAS: Phantom 2, Phantom 3, and Inspire 1 precisely within the FAA UAS guidelines as we ll as those which accompany DJI Phantom 2, DJI Inspire 1, and DJI Phantom 3 Operator’s manuals. Each petitioner’s UAS are equipped with detachable cameras , GPS tracking and guidance, and are always transported o r stored safely . This proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the purpose of aerial videography/ photography as a service to the public/ business interests. As found in exemption No. 11138 (Trudeau), the FAA recen tly approved similar use of a Phantom 2 UAS. All of these devices are equipped with many safety features that , when utilized with following the petitioner’s strict safety protocol before each flight , have proven to be a reliable, safe, and environmentally friendly way to provide aerial imaging services. The petitioner’s UAS fleet all utilize gyro stabilized flight, ground detection (phantom 3 and inspire 1), GPS aided navigation, a compass, blinking LEDs, failsafe mode fo r returning home, and voice confirm ation of real time flight information . This will act to further safety protocols exclusive to lightweight UAS’s specific to vi deo and photography usage as I record flight data and other information gained through permitted flight operations to share with t he FAA through any required FAA reports to assists with future protocol and safety regulations. The petitioner has been and receives ongoing aeronautics training from our PIC, a certified FAA private pilot, Robert Kinsey, ( FAA license number undisclosed since social security numbers are used in these cases) to ensure all FAA safety protocols are administered before, during, and after each flight. The petitioner has and will continue to keep current aviation insurance for each UAS to protect t he public ’s interest and property from any accidental damage in the event of a collision.**Specific section or sections of 14 CFR which I seek relief and the reason I seek**

**relief:** 14 C.F.R. Part 21: Airworthiness Certificates The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements outlined in Petitioners Operations Manual. Given the size and limited operating area associated with the UAS to be utilized by the petitioner, an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the reform Act. 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, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UAS will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command The petitioner utilizes our PIC, Robert Kinsey, FAA certified private pilot , for aeronautics training and safety . T he FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAS in question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and pla card requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes The petitioner will ensure that UAS do not operate any higher than 400 feet at ground level. The petitioner will not fly over congested areas of pedestrians or wildlife . I w ill plan operations before hand, for proper flight safety, and proper height analysis to maintain maximum safety for each flight.14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety is achieved by setting applicable altitude limits according to the DJI operations manual as we ll as voice recognition from the ground control unit

. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions The UAS that I will fly are powere d by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) a nd (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. The petitioner will always fly safely under strict direction from our PIC Robert Kinsey, certified FAA private pilot, and the manuals of the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Ma intenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. The petitioner will perform preflight inspections of the UAS before each flight as outlined in the operating documents. The petitioner will also follow manufacturer recommendations from said operating documents. **Public Interest** Aerial photography and videography as an available se rvice to the public allows for a safer, less expensive, and environmentally friendly alternative to manned aircraft and helicopters. They are expensive, create lots of noise, and are much more threatening due to size and combustible fuel. The petitioner would eagerly offer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public. Also as mentioned in the Trudeau exemption, exemption No.11138: ““Manned aircraft conduct ing aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as we ll as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be re motely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident oraccident. The risk of an onboard pilot and crew during an incident or accident is

eliminated with the use of a [sUAS] for the proposed operation.” **Summary** The petitioner, Wi lliam Richard of Director’s Chair Productions, LLC , is seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b) Wi th the exemptions of the mentioned rules the petitioner will be seeking to make my aerial photography/videography services available to the public. Alternatively the public had saut to use helicopters and aircraft to achieve what the petitioner can offer in a safer, more cost efficient manner. The U AS operated by the petitioner are not using combustible fuel, always fly at safe heights , and strictly following the usage recommendations from DJI as well as all FAA regulations

. These include but are not limited to:

 ● Flying the following UAS Safely : ○ DJI Inspire 1 ○ DJI Phantom 2 ○ DJI Phantom 3

 ● Flying below 400 feet

 ● Proper visual inspection of UAS before flights

 ● Keeping mentioned UAS in visual sight at all times when in operation

 ● Using an observer to assist if needed

 ● Remain we ll clear of and do not interfere with manned aircraft operations, and avoid other aircraft and obstacles at all times

 ● Not intentionally fly over unprotected persons or moving vehicles

 ● Contact the airport or control tower before flying within 5 mile s of an airport

 ● Not flying in adverse weather conditions such as high winds or reduced visibility

 ● Not flying under the influence of alcohol or drugs

 ● Ensure the operating environment is safe

 ● Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc.

 ● Check and follow all local laws and ordinances before flying over private property

 ● Do not conduct surveillance or ph otograph persons in areas where there is an expectation of privacy without the individual's permission. Sincerely, Wi lliam Paul Richard, Director’s Chair Production, LLC 5239 Pembroke Way, San Ramon, CA 94582, 510

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- 0655, dcpbayarea@gmail.com www.directorschairproductions.com