October 21, 2014

United States Department ofTransportation Docket Operations 1200 New Jersey Ave.SE WestBuilding Ground Floor Room W12-140 Washington DC 20590 Re: Exemption RequestPursuant To Section 3 3 3 ofthe FAA Reform Act of2012

Dear Sir orMadam: I am writing pursuantto the FAA Modernization and Reform Act of2012 (the "ReformAct") and the procedures contained in 14 C.F.R. 11, to request thatDrone Zone LLC, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations (FAR's) listed below so that Drone Zone, may operate its small unmanned aircraft/lightweightunmanned aircraft systems (UAS) commercially in airspace regulated bythe FederalAviation Administration (FAA); as long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. As identified and described herein, ScottZimmerman, and his company Drone Zone LLC, is an experienced, licensed, and insured RIC modelpilot (25yrs) and comes from a family ofpilots. His Father, a pilotwith the Minnesota DOT, and Uncle a retired commercialpilotwith United Airlines. With this background, Scott Zimmerman has a full and unique understanding ofthe safety precautions, and laws thatmustbe observed and adhered to. Drone Zone LLChas been actively involved inthe technical development ofUASIUAV service applications to provide high definition film quality by aerial cinematography with small, unmanned aircraft and lightweightUASs.ltis currently one ofthe very few companies that is developing advanced technical applications and abilities for future commercial service applications. Drone Zone LLC has fully equipped each ofits small unmanned aircraft for aerial photography and cinematography. Through given their stability and maneuverability, they may be used for other cinematography, by law enforcementpersonnel, search and rescue and by otherfirst responders.

To Date, Drone Zone LLC has rejected all offers to work with film, television, commercial television production companies and directors on locations within the United States to ensure it is in compliance with any applicable FARs. It, like other applicants, has done so despite Judge Patrick G.

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Geraghty's decision in the Rapheal Pirkermatter and his reasoning thatno FARs prohibits the use of small unmanned aircraft or lightweightUASs like those flown by otherpeercompanies. Drone Zone LLC exemption requestwould permit its operation oflightweight, unmanned (remotely controlled in line ofsight) UASs in tightly controlled and limited airspace. Predetermined, specifically marked areas ofoperation cordoned offlocations and corresponding enhancements to current safety controls will allow Drone Zone LLC to operate within current safety parameters and new ones being implemented. As identified, similar lightweight, remote controlled UASs are legally operatedby amateurs with no flight experience, safety plan or controls in place to prevent catastrophe. Drone Zone LLC is developing a state-of-the art clientwebsite application to monitor, evaluate and implement all aerial cinematography activities with a pre-flight safety and flight plan system. Granting Drone Zone LLC request comports with the Secretary ofTransportation's (FAA Administrator's) responsibilities to not only integrate UASs into the national airspace system, butto "

...establish requirements for the safe operation ofsuch aircraft systems (UASs) in the national airspace system" under Section 333© ofthe Reform Act. Further, Drone Zone LLC will conduct its operations in compliance with the protocols described herein or as otherwise established by the FAA. Drone Zone LLC respectfully requests the grant ofan exemption allowing itto operate lightweight, remote controlled UAS's. The Specific Sections ofTitle 14 ofFederal Regulations, Drone Zone LLC requests exemption are: 14 CFR21; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 14 C.F.R. 91, et seq; 14 CFR407 (a) (I); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21;14 CFR 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) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). The ExtentofRelief Drone Zone Services Seeks and the Reason it seeks SuchRelief: Drone Zone LLC submits this application in accordance with the Reform Act, 112 P.L. 95 ss 331-334, seeking relieffrom any currently applicable FARs operating to preventDrone Zone LLC contemplated commercial cinematic, research and other flight operations within the national airspace system. There Reform Actin Section 332 provides for such integration ofcivilunmanned aircraft systems into ournational airspace systems into ournational airspace system as it is in the public's interestto do so. Drone Zone LLC lightweight UASs meetthe defmition of"smallunmanned aircraft: as defmed in Section 331 and therefore the integration ofNetworkMedia Services lightweightUASs are expressly contemplated bythe Reform Act, Network Media Services would like to operate its lightweightUASs priorto the time periodby which the Reform Actrequires the FAA to promulgate rules governing such craft.

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The Reform Actguides the Secretary in determining the types ofUASs thatmay operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS; Whetherthe UAS will be operated near airports orpopulated areas; and, Whether the UAS will be operated by line ofsight. 112 P.L. 95 s 333 (a). Each ofthese items militates in favor or an exemption for Network Media Services. Drone Zone LLC UASs utilizes three to four counter-rotating propellers for extreme balance, control and stability. They each weigh less than 55 pounds, including cinematic or otherequipmen. Each ofDroneZone LLC small unmanned aircraft are designed to primarily hoverin place and operate at less than a 50 knotmaximum speed. They are capable ofvertical and horizontal operations but operate only wihin the line ofsight ofthe remote control pilot. In addition to the remote controlpilot, Drone Zone LLC uses a spotter and a technician, such that, atminimum, three Drone Zone LLCs personnel govern the safe flight ofan Drone Zone LLC aircraft at all times. Utilizing battery powerand notcombustible fuels, flights generally lastbetween five and twenty minutes. Drone Zone LLC des notoperate its UASs with less than twenty five percentbattery capacity. Safety systems in place include a GPS mode that allows Drone Zone LLC UASs to hover in place ifcommunication with the radio controlpilotis lost and then slowly descend the UAS attwenty five percentbattery capacity. Further, Drone Zone LLC fleet is programmed, in some instances, to slowly follow a predetermined set ofwaypointsto return to a safety point ifcommunications are lost. Drone Zone LLC does notoperate its UASs near airports and generally does not operate them nearpopulated areas. The UAS operating software and GPS navigation systems do not allow any ofthe Drone Zone LLC UAS vehicles to operate near airports orrestricted fly zones. The failsafe software will disable the UAS vehicles from taking offand also limitthe fly zones. The failsafe software will disable the UAS vehicles from taking offand also limitthe UAS systems from operating within specific GPS presentno-fly zones. To date, Drone Zone LLC has only operated its fleet on private property cordoned offareas underthe control ofDrone Zone LLC clients. Drone Zone LLC only operates its UASs in predetermined areas and only in compliance with well-regarded safety protocols. Drone Zone LLC operation ofits fleet ofsmallunmanned aircraft will not "create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 s 333 (b). Given the small size and weight ofDrone Zone LLC UASs, combined with their operation in cordoned offand well-controlled areas, Drone Zone LLC fleet falls within Congress;;s contemplated safety zone when itpromulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Indeed, Drone Zone LLC UASs have a demonstrable safety record and do notpose any threatto the generalpublic ornational security. The FAAhas the authority to issue the exemption to Drone Zone LLC pursuantto the Federal Aviation Ace, 85 P. L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits.

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Granting Drone Zone LLC exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing ofthe Reform Act. Second, Drone Zone LLC conducts research into safe UAS operations every time it flies one ofits UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Allowing Drone Zone LLC to log more flight time directly relates to its research and its ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with current aerial capture methods, namely, full size helicopters. Drone Zone LLC UASs are battery powered and create no emissions. Ifa Drone Zone LLC lightweightUASs is far less than a full size helicopter, notwithstanding the statistically noteworthy safety record offull size helicopters. Drone Zone LLC UASs are batterypowered and create no emissions. Ifa Drone Zone LLC crashes there is no fuel to ignite and explode. The impact ofDrone Zone LLC lightweightUASs is far less than a full size helicopter, notwithstanding the statistically noteworthy safety record offull size helicopters used in aerialphotography. The public's interest is furthered by minimizing ecological and crash impacts bypermitting aerialphotography through Drone Zone LLC lightweightUASs. Progression ofthe arts and sciences has been fundamental to our society since its inclusion in the United States Constitution. Indeed, Congress mandates the integration ofUASs into ournational airspace system, in part, to achieve progression in the noteworthy, and inevitable, field. Permitting Drone Zone LLC to immediately fly within the United States furthers these goals. Whether itis the amalgam ofscientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or advancements in equipment available to law enforcementpersonnel/firstresponders that does notcostmillions ofdollars, granting Drone Zone LLC exemption request substantially furthers the public's interest in ways known and currently unknown.

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Reasons Why Drone Zone LLC ExemptionWill NotAdversely Affect Safety or Howthe Exemption Will Provide a Level ofSafety at LeastEqual to Existing Rule: Drone Zone LLC exemption will not adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting Drone Zone LLC to log more flight time in FAA controlled airspace will allow Drone Zone LLC to innovate and implementnew and as ofyetundiscovered safety protocols. In addition, Drone Zone LLC submits the following representations ofenhancements to current aerial picture capture techniques:

• Drone Zone LLC UASs weigh less than 55 pounds complete with digital cameras • Drone Zone LLC only operates its UASs below 400 feet; • Drone Zone LLC UASs only operate for 5-25 minutes perflight; • Drone Zone LLC lands its UASs when they reach 25%battery power; • Drone Zone LLC remote controlpilots operate Drone Zone LLC UASs by line ofsight; • Drone Zone LLC remote controlpilots have video backup should they somehow lose sight ofthe UAS; • Drone Zone LLC staffs each flight with a remote controlpilottechnician and spotter with communication systems enabling realtime communication betweenthem; • Drone Zone LLC UASs have GPS flight modes whereby they hover and then slowly land ifcommunication with the remote controlpilotis lost orbattery power is below 25% • Drone Zone LLC actively analyses electronic flight data and other sources of information to constantly update and enhance safety protocols; • Drone Zone LLC only operates in secured areas that are strictly controlled, are away from airports and populated areas; • Drone Zone LLC conducts extensive briefmgs priorto flight, during which safety carries primary importance; • Drone Zone LLC always obtains all necessary permission and permits priorto operation; and, Drone Zone has procedures in place to abort flights in the eventof safety breaches orpotential danger.

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Drone Zone LLC provides a level ofsafety atleast equalto existing rules, and in nearly every instance, greaterthan existing rules. Itis importantto note that absentthe integration ofcommercial UASs into ournational airspace system, helicopters are the primary means ofaerialphotography. While the safety record ofsuch helicopters is remarkably astounding, it is far saferto operate a battery powered lightweightUSAS. First, the potential loss oflife is diminished because UASs carry no people ofboard and Drone Zone LLs only operates them in specific areas away from mass populations. Second, there is no fuel onboard a UAS and thus the potential for fire explosions is greatly diminished. Third, the small size and extreme maneuverability ofDrone Zone LLs UASs allow ourremote control pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture amazing images, Drone Zone LLC UASs need notbe so close to the objects they are focused on. Accordingly, Drone Zone LLC UASs have operated and will continue to operate at an above current safety levels. A summary The FAAMay Publish in the FederalRegister: A. 14 C.F.R. 21 and 14 C.F.R. 91; Airworthiness Certificates, Manuals and The like. 14 C.F.R. 21, SubpartH, entitled Airworthiness Certificates, sets forth requirements for procurementofnecessary airworthiness certificates in relation to FAR s 91.203(a){l). The size, weight and enclosed operational area ofDrone Zone LLC UASs permits exemption from Part 21 because Drone Zone LLC UASs meet an equivalentlevel ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirementunderboth the Act (49 U.S.C. s 44701 (f)) and Section 333 ofthe Reform Act. Bothpieces oflegislationpermitthe FAA to exemptUASs from the airworthiness certificate requirementin consideration ofthe right, size, speed, maneuverability andproximity to areas such as airports and dense populations. Drone Zone LLC UASs meetto exceed each ofthe elements.

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14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate willbe applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. s 91.9(b)(2) requires an aircraft flight manualin the aircraft. As there are no pilots or passengers, and given the size ofthe UASs this Regulation is inapplicable, An equivalent level ofsafety willbe achievedby maintaining a manual atthe flight operations center. The FAAhas previously issues exemptions to the regulation in ExemptionNos. 8607, 8737, 8738, 9299, 9299A,9565,9565B, 10167, 10167A, 10602,10700,32827. B. 14 C.F.R. s 45.23: Marking ofThe Aircraft Applicable codes ofFederalRegulation require aircraftto be marked according to certain specifications. DroneZone LLC UASs are, by defmition, unmanned. They therefore do nothave a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, two-inch lettering is difficultto place on such small aircraft. Regardless, Drone Zone LLC will mark its UASs in the largest possible lettering byplacing the work "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. s 45.29(t) so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issues exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R s 61.113: Private PilotPrivileges and Limitations: PIC Pursuantto 14 C.F.R. ss 61.113(a) & (b), private pilots are limited to non-commercial operations. Drone Zone LLC can achieve an equivalent level ofsafety as achievedby currentRegulations because Drone Zone LLC UASs do notcarry any pilots orpassengers. Further, while helpful, a pilotlicense will notensure remote controlpiloting skills, though Drone Zone LLC pilotvetting and training programs will. Further, privatepilotlicensees will operate Drone Zone LLC UASs with the same skill. Further, the risks attendantto the operation ofDrone Zone LLC UASs is far less than the risk levels inherentin the commercial activities outlines in 14 C.F.R. s 61, et seq. Thus, allowing Drone Zone LLC to operate its UASs with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. s 61.113(a) & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

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14 C.F.R. 91.119 prescribes safe altitudes for the operation ofcivil aircraft. Itallows helicopters to be operated at lower altitudes in certain conditions. Drone Zone LLC UASs will never operate at an altitude greaterthan 400 AGL. Drone Zone LLC will, however, operate its UASs in cordoned offareas with security providing a level ofsafety atleast equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofDrone Zone LLC UASs, an equivalent level ofsafety will be achieved. E. 14 C.F.R 91.405 (a); 407 (a) (1);409 (a) (2);417 (a)&9b): Maintenance Inspections. The above-cited regulations require, amongst otherthings, aircraft owner and operators to have [the] aircraft inspected as prescribed in subpartE ofthis part and shall betwen required inspections, except as provided in paragraph ( c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter. These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Drone Zone llc should its requested exemption be granted. Drone Zone conduct an extensive maintenance program that involves regular software updates and constantinspection for assessment of any damaged hardware. Therefore, an equivalent level ofsafety willbe achieved. Drone Zone has researched and developed it's own designs. F. Summary Drone Zone llc. seeks an exemption from the following regulations: 14 C.F.R. 21, subpartH; 14 C.F.R45.23(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. § 91.109; 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) & (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. § and, 14 C.F.R. §§ 91.4179(a) & (b) to commercially operate its fleet ofsmall, light, unmanned aircraft for the purposes ofaerialphotography/video, and to conduct its own research, and develop platforms for first responders,search and rescue. Granting Drone Zone llc. requestfor exemption will reduce currentrisk levels and thereby enhance public safety. Currently the aerial photography industry relies primarily onthe use on full scale, large aircraftrunning on combustible fuel. Drone Zone llc. craft do notcontain potentially explosive fuel, are smaller, lighter, and more maneuverable than conventional aerial cameraplatforms. Further, Drone Zone llc. operated atlower altitudes and in controlled airspace. Drone Zone llc. has been analyzing

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flight data and otherinformation in compiling novel saftey protocols and the implementation ofa flight operations manualthat exceeds currently accepted means and methods ofsafe flight. There are no people on board Drone Zone llc. UA V's andtherefore the likelihood ofdeath or serious bodily injury is significantly limited. Drone Zone llc. UA V's weigh less than 55 lbs. and travel at speeds less than 50 knots in cordoned offareas will provide at least an equivalent level ofsafety as that achieved under currentF ARs. Drone Zone llc. Respectfully requests thatthe FAA grant its exemption requestwithout delay. The FAA has the authority to issue the exemption soughtby Drone Zone llc pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "act")

Sincerly,

# z~~ ScottZimmerman Drone Zone llc. 1980 HoytAve. E. St. Paul, MN. 55119

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