July 10, 2015

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

RE: Exemption Request Section 333 of the FAA Reform Act

To whom it may concern,

Light Control is a full service lighting design firm with a focus on sustainable architectural and landscape lighting serving the Scottsdale area.

This document requests an exemption under Section 333 of the FAA Modernization and Reform Act of 2012 for Aviation Unmanned to perform aerial photography/videography by Light Control. The primary use of this Unmanned Aircraft System (UAS) is to obtain aerial photos, video and/or digital media to utilize for commercial purposes and services. Details of the UAS, the DJI Phantom 3, is referenced in this document.

The requested exemption would permit Light Control to pursue commercial interests and services in the following areas:

• Design

• Marketing

• Real Estate and Architecture

• Surveying and Mapping

• Photometric Light Analysis

• Review of Installation and Construction

• Educational Material

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.comA. Address and Contact Information:

Kevin J. Flower Principal

Light Control 15220 N 78th Way Scottsdale, AZ 85260

O ffi ce: 480-621-5442 Mobile: 602-448-5007

kevin@lightcontrolaz.com

lightcontrolaz.com Tyler T. Hollmann Programmer/Sustainability Consultant

Light Control 15220 N 78th Way Scottsdale, AZ 85260

O ffi ce: 480-621-5442 Mobile: 928-202-8539

tyler@lightcontrolaz.com

lightcontrolaz.com

B. Sections of 14 C.F.R from which Light Control seeks exemption:

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 3. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 4. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 5. 14 CFR 91.119 Minimum Safe Altitudes. 6. 14 CFR 91.121 Altimeter Settings. 7. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 8. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations. 9. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e) (1) Observer Medical.

C. Public Interest Benefits:

Light Control wishes to create a low-risk, managed, and e ffi cient platform for acquiring photos, video and digital media for purposes stated above. The use of the UAS provides a platform that is unobtrusive, less energy intensive, and safer

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.comto its surrounds. This would allow Light Control to educate the public, design industry, and construction industry into the benefits and uses of the UAS platform. This in turn will create an informed public institution.

D. Introduction to UAS

UAS are a compact and e ffi cient tool used in aerial photos, video, and digital media gathering due to more a ff ordable equipment and personnel cost, reduced noise, and a much smaller environmental impact

. Light Control is seeking exemption in order to operate the DJI Phantom 3 (manufacturer technical specifications included below) UAS which includes built in GPS and image/ultrasound positioning systems as well as the following features:

• Restricts the height above ground level (AGL) to a specified user-generated

height.

• Restricts the radius of flight from the ground station, takeo ff location and base of aerial operations, to a user-generated radius.

• Restricts operations within designated airspace with the support of a built-in

no-fly zone feature.

• The DJI Phantom 3 also has an integrated failsafe function that is triggered in

the event communications are lost between the UAS and the remote controller. In the unlikely event this occurs, the UAS will ascend to a defined altitude, return to its point of takeo ff , and land safety. If communications are restored, the pilot in command (PIC) can regain control of flight and land manually.

Aircraft Technical Specifications: Weight (Battery & Propellers Included) 1280 g

Max. Ascent Speed 5 m/s

Max. Descent Speed 3 m/s

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.comMax. Speed 16 m/s (ATTI mode, no wind)

Max. Flight Time Approximately 23 minutes

Remote Controller Specifications: Operating Frequency 2.400 GHz-2.483 GHz

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm

E. Operation Guidelines

1. Operations are limited to the DJI Phantom 3. 2. The UAS will weigh less than 55 pounds including payload. 3. The UAS will not exceed the speed of 87 knots (100 miles per hour). 4. The UAS will be operated at an altitude of no more than 400 feet AGL. 5. The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. 6. All operations will utilize a visual observer (VO). The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. 7. Operating documents and property use agreements/authorization will be available at the ground station. 8. Functional testing flights will be conducted by a PIC with a VO. 9. Light Control will maintain and inspect the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in safe flight condition. 11. The UAS will be operated in compliance with all manufacturer safety bulletins and boundaries. 12. The UAS will not be operated within 5 nautical miles of an airport reference point (ARP).

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com13. The UAS will not be operated 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. 14. If the UAS loses communications or loses its GPS signal, the UAS will return to a pre-determined location within the private or controlled-access property. 15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 16. All operations will be conducted over private, public, or controlled-access property with permission from the property owner/controller/public authority or authorized representative. Permission from property owner/ controller/public authority or authorized representative will be obtained for all flights to be conducted.

We respectfully request exemption under Section 333 to permit Light Control to conduct e ffi cient, limited, and low-risk commercial UAS operations for the activities stated herein while respecting at all times the space and privacy of citizens and property, and following the incurred FAA regulations.

Sincerely,

Kevin J. Flower Principal Tyler T. Hollmann Programmer/Sustainability Consultant

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com