From: E20N5250 S. Hardy Drive, Apt 2101 Tempe, AZ 85283-5214 To: U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Ave., SE Washington DC 20590**.~**;_:**~**l r.Cj Re: Exemption Request Pursuant to Section 333ofthe FAA Reform Act and Part IIofthe Federal Aviation Regulations from: 14 CFR 45 .23(b); 14 CFR 21;14 CFR 61.113(a)&(b); 14 CFR 61.113(a)&(b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119(c); 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a)(l); 91.409(a)(1)&(2); 91.417(a)&(b). January 18, 2016 Dear Siror Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Actof 2012 (the

"Reform Act") and 14 C.F.R. Part 11, E20N ("Applicant"), an operator of Unmanned Aircraft systems ("UAs") for aerial transportation, surveillance, photography, and

filming operations fora range of business applications including aerial deliveries, insurance, real estate, agriculture, infrastructure inspection, 3D mapping, disaster relief assistance, travel video/photography, motion picture, television, and internet video production hereby applies foran exemption from the Federal Aviation Regulations ("F ARs") to allow commercial operation ofits UAs. To date, the FAA granted numerous exemptions toUAs operators. The Applicant's requested exemption would permit the operation of small, unmanned UAs under "controlled" and "sterile" airspace thatis:(i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safety in connection with aircraft operations inlast mile deliveries, aerial surveillance, film and television industries. As established by the exemptions already granted by the FAA, approval ofthe Applicant's exemption would enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to"... establish requirements forthe safe operation of such aircraft systems inthe National Airspace System (NAS)." Section 333(c) ofthe Reform Act- The name, address and point of contact for the applicant is: E20NCraig Arsenych 5250 S. Hardy Drive, Apt 2101 Tempe, AZ 85283-5214 + 1(530) 409-8139

j:**I.~**{jP(lge2of12 This exemption application is expressly submitted to fulfill Congress' goalin passing Section 333(a) through (c)ofthe Reform Act. This law directs the Secretary of Transportation to consider whether certain Unmanned Aircraft systems (UAs) may operate safely inthe National Airspace System (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this Determination, the Secretary is required to determine which types ofUAs do not create a hazard to users ofthe NAS orthe public or posea threat to national security in light ofthe following:

•The UA's size, weight, speed, and operational capability • Operation ofthe UAsin close proximity to airports and populated areas and • Operation ofthe UAs within visual lineof sight (VLOS) ofthe operator. The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority byits terms includes exempting civil aircraft, asthe term is defined under §40 101 ofthe Act that includes UAs from the requirement that all civil aircraft must havea current airworthiness certificate. UAs operated bythe Applicant weigh less than 55 pounds, including the payload (i.e. cargo, camera, lens, and gimbal). They operate at speeds ofno more than 50 knots, can hover, and can simultaneously move vertically and horizontally. The Applicant will only operate its UAsin VLOS and will operate only within the sterile area. Such operations will insure that the UAs will "not create a hazard to users ofthe national airspace system, orthe public." The Applicant seeks an exemption to operate itsDJI Phantom 3 Professional (N625NC) UAs for compensation, or hire within the NAS. A copy ofthe operating handbook for this aircraft will be submitted with this exemption request. The Applicant's UAs hasa maximum gross weight under 5 pounds (including payload),

maximum speed of49 mph (approximately 42 knots) andarun time of approximately 30 minutes. The UAs operated bythe Applicant is registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking (aircraft registration number N625NC). Given the small size ofthe Applicant's UAs and the restricted sterile environment within which itwill operate, the Applicant's UAs operations adhere tothe Reform Act's safety requirements. Additionally, duetothe sizeofthe UAs and the limited areas in which itwill operate, approval ofthis application presents no national security issues. Based onthe substantial level of safety surrounding the proposed operations, the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant ofthe requested exemption isinthe public interest.Page3 of12 Accordingly, the Applicant respectfully requests that the FAA grant the requested

exemption without delay. Aircraft and equivalent level of safety The Applicant proposes that the exemption requested apply to civil aircraft that have the characteristics and that operate within the limitations listed. These limitations provide forat least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations

represent a safety enhancement tothe already safe aerial photography and filming for movie and television filming operations conducted with conventional aircraft. These limitations and conditions to which the Applicant agrees tobe bound when conducting commercial operations under an FAA issued exemption include: 1.The UAs will weigh less than 55lbs. 2. Flights willbe operated within VLOS ofapilot and/or observer. 3. Maximum total flight time for each operational flight will be30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior tothe30 minute limit. 4. Flights willbe operated atan altitude ofno more than 400 feet AGL. 5. Minimum crew for each operation will consist ofthe UAs Pilot In Command (PIC) and the Visual Observer. 6.UAs PIC will bean FAA licensed airman with at leasta Sport Pilot's Certificate. 7.UAs PIC assumes all duties and responsibilities. 8.The UAs will only operate within a confined "Sterile Area." Security will be performed bythe PIC and designated security personnel. 9.A briefing will be conducted in regard tothe planned UAs operation(s) prior to each day's activities. Itwill be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be present for this briefing. 10. The PIC will obtain the consent ofall persons. 11. When required, the PIC will submit a written Plan of Activities tothe nearest FSDO seventy-two (72) hours prior the proposed flight operation. 12. PIC and observer will have been trained in operation of UAs generally and received up-to-date information onthe particular UAstobe operated. 13. ALL crewmembers willatall times be ableto communicate by ONLY voice

to ensure all crew members maintain visual contact with the UAsatALL TIMES. 14. Written and/or oral permission from the relevant property holders will be obtained.15.All required permissions and/or permits shall be obtained from territorial, state, county, or city jurisdictions including local law enforcement, fire, or other appropriate governmental agencies as necessary. 16.Ifthe UAs loses communications, or loses its GPS signal, the UAs will have the capability to return toa pre-determined location within the Security Perimeter and land.Page4 of12 17. The UAs will have the capability to abort a flight in case of unpredicted obstacles oran unexpected emergency. Plan of Activities -The Plan of Activities shall include the following: Briefing1. Date(s) and time(s) forall flight(s). 2. Name and phone number ofthe person(s) responsible forthe event. 3. Name and phone number ofthe person(s) responsible forthe aircraft. 4. Make, model, serial number and registration number ofallUAstobe used. 5. Name and certificate number, if applicable, ofall crewmembers tobe utilized in the event including copies ofFAA Medical Certificates and endorsements.

6.A statement that the Waiver Holder has obtained permission from property owners and/or local governmental officials to conduct the event. 7. Signature of Waiver Holder, or representative. 8.A description ofthe flight activity including maps or diagrams ofany area, city, town, county, and/or State over which flight will be conducted and the minimum altitudes essential to accomplish the operation. The Applicant and the event representative will conduct a verbal and written briefing for the members involved, including emergency, if applicable, and security personnel. This briefing will be conducted prior to each day's UAs activities and will include the following items: 1. Authorization UAs flight operations, Plan of Activities, special provisions and any additional provisions issued by the Flight Standards District Office having jurisdiction over the flight area. 2. Radio communications. 3. Takeoff procedures. 4. Aviation activities tobe conducted during the event. 5. Approach and landing procedures. 6. Alternate landing zone inthe event of emergency or security breach. 7. Recall procedures. 8. Emergency procedures. 9. Possible riskto personnel that are involved. 10. Control of non-participating persons. 11. Location of boundaries or deadlines, man-made or natural, readily visible tothe participants.13. Local governmental limitations, restrictions, orany special circumstances, such as noise sensitive areas, time of day restrictions, or changes in operating procedures. Security -The exclusion from flight operations area of unauthorized persons, vehicles, or aircraft will be enforced by designated event personnel, private security officers, or sworn law enforcement officers atthe direction ofthe Applicant.Page5of12 The Applicant or designated representative will halt flight operations inthe event unauthorized persons, vehicles· or aircraft enter the flight operations area. A predetermined abort signal will be used tohalt flight operations should a breach of perimeter security occur, orfor any other reason inthe interest of safety. Alternate UAs landing sites will be made available prior tothe start ofthe event. Regulations from which the exemption is requested: 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a)&(b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a)&(b) 14 CFR 91.405(a) 14 CFR 407(a)( I) 14 CFR 409(a)(2) 14 CFR 417(a)&(b) 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §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 tobe utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701(t)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAs. Inall 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 beat least as safe, or safer, thana conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAstobe operated hereunder isless than 55 lbs., fully loaded, carries neither a pilot nor passenger, carries no explosive materials, or flammable liquid fuels, and operates exclusively within a secured area asset outinthe Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored bythe PIC, pursuant tothe Manual's requirements, in compliance withPage6of12 local public safety requirements, to provide security for the area of operation asis now done with conventional flight**ope~~ations.** The FAA will have advance notice ofall flight operations. These safety enhancements, which already apply to civil aircraft operated in connection with transportation, motion picture and/or television production provide a greater degree of safety tothe public and property owner( s) than conventional operations conducted

with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there isno credible threat to national security posed by the UAs, duetoits size, speed, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external payload. 14 CFR§ 45.23(b)- Marking ofthe Aircraft The regulation requires: 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 tothe cabin, cockpit, or pilot station, in letters not less than two

(2) inches nor more than six (6) inches high, the words "limited", "restricted", "Light-sport", "experimental", or "provisional" as applicable. Even though the UAs will have no airworthiness certificate, an exemption may be needed asthe UAs hasno entrance tothe cabin, cockpit or pilot station on which the word "experimental" canbe placed. Given the sizeofthe UAs, two (2) inch lettering

will be impossible. The word "Experimental" will be limited to1hinch lettering placed onthe UAsin compliance with §45.29(f). The equivalent level of safety will be provided by having the UAs marked onits underbody as required by §45.29(f) where the PIC, observer and others working with the UAs will see the identification ofthe UAsas "Experimental." The FAA has issued the following exemptions tothis regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 14 C.F.R. § 61.113(a)&(b)- Private Pilot Privileges and Limitations. Pilot in Command (PIC). Sections 61.113(a)&(b) limit private pilots to noncommercial operations. Because the UAs will not carry a pilot, or passenger(s), the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to havea private pilot's license, orat least

a Sport Pilot's Certificate, rather thana Commercial pilot's license to operate smallPage7 of12 UAs. Unlike a conventional aircraft that carries the pilot and passenger(s), the UAs is remotely controlled with no living thing on board. The area of operation is controlled and restricted, andall flights are planned and coordinated in advance as set forth inthe Manual. The level of safety provided exceeds that provided bya single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe UAs areso diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe UAsas requested witha private pilot asthe PIC exceeds the present level of safety achieved by14 CFR §61.113(a)&(b). 14 C.F.R §91.7(a)- Civil aircraft airworthiness. The regulation requires that no person may operate acivil aircraft unless itisin airworthy condition. As there will beno airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained inthe Manufacturer's Operating Manual for maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided. 14 CFR§ 91.9(b)(2)- Civil Aircraft Flight Manual inthe Aircraft. Section 91.9(b)(2) provides: No person may operate (1)aU.S. registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual isnot required by §21.5 ofthis chapter, unless there is available inthe aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.The UAs, given its size and configuration has no ability or place to carry a flight manual onthe aircraft, not only because there isno pilot on board, but because there isno room or capacity to carry such an item onthe aircraft. The equivalent level of safety will be maintained by keeping the flight manual atthe ground control point where the PIC flying the UAs will have immediate access toit.

The FAA has issued the following exemptions tothis regulation: Exemption No's: 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167 A, 10602, 32827, and 10700.Page8of12 14 CFR§ 91.103- Preflight action This regulation requires each PICto take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 CFR §91.109- Flight instruction Section 91.103 provides that no person may operate acivil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. UAs and other remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the useofa single control box that communicates with the aircraft via radio communications.The FAA has approved exemptions for flight training without fully functional dual controls fora number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety can be achieved as neither a pilot, nor passenger(s) will be carried inthe aircraft in addition tothe small size and low speed ofthe aircraft.14 CFR §91.119- Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters tobe operated atless than the minimums prescribed,

provided the person(s) operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption isforaUAs that isa multi-rotor and the exemption requests authority to operate at altitudes upto 400 feet AGL, ornot more than 200 feet above an elevated platform from which operation is planned, an exemption may be needed to allow such operations. Asset forth herein, except for the limited conditions stated inthe Manual, the UAs will never operate at higher than 400 feet AGL. Itwill however be operated ina restricted area with security perimeter, 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 ofthe UAs, as well asthe location where itis operated. No flight will be taken without the permission ofthe property owner, or local officials. Because ofthe advance notice tothe property owner and participants inthe flight activity, all affected individuals will be aware ofthe planned flight operation(s). Compared to flight operation(s) with aircraft, or rotorcraft weighting far more than the maximum 55lbs proposed herein and the lack of flammable fuel, any riskPage9 of12 associated with these operations isfar less than those presently presented with conventional aircraft operating ator below 500 feet AGL. In addition; the lowaltitude operations ofthe UAs will ensure separation between these small-UAs operation(s) and the operation(s) of conventional aircraft that must comply with Section 91.119. 14 CFR §91.121- Altimeter Settings This regulation requires each person operating an aircraft to maintain altitude by reference toan altimeter thatis"settothe elevation ofthe departure airport oran appropriate altimeter setting available before departure." Asthe UAs may not have a barometric altimeter, but instead aGPS altitude read out, an exemption may be needed.An equivalent level of safety will be achieved bythe PIC, pursuant tothe Manual and

Safety Checklist, by receiving altitude information viaa digitally encoded telemetric

data feed, which downlinks from the aircraft toa ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, orany combination thereof. Prior to each flight, azero altitude initiation point willbe established and confirmed for accuracy bythe pilot. 14 CPR§ 91.15l(a)- Fuel Requirements for Flight inVFR Conditions Section 91.151(a) prohibits an individual from beginning a flight inan airplane

under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point of intended landing, and, assuming normal cruising speed: (1) During the day,tofly after that forat least 30 minutes, or (2)At night, tofly after that forat least 45 minutes. The battery powering the UAs provides approximately 40 minutes of powered flight.

To meet the 30-minute reserve requirement in14 CFR §91.151, UAs flights would be limited to approximately 10 minutes in duration. Given the limitations onthe UA's proposed flight area and the location ofits proposed operations within apredetermined area,a longer time frame for flight in daylight or night VFR conditions is reasonable.The Applicant believes that an exemption from 14 CFR §91.15l(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAs, ina tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than

thirty (30) minutes of reserve fuel, does not engender the type of risks that Section 91.15l(a) was intended to alleviate given the size and speed ofthe small UAs. Additionally, limiting UAs flights toten (10) minutes would greatly reduce the utility for which the exemption will be granted.Page 10 of12 The Applicant believes that an equivalent level of safety canbe achieved by limiting flights to thirty (30) minutes, or 25% of reserved battery power whichever happens

first. This restriction would be more than adequate to return the UAstoits planned landing zone from anywhere inits limited operating area. 14 CFR §91.203(a) &(b)- Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate acivil aircraft unless ithas the following: (1)An appropriate and current airworthiness certificate .... (b)No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a)ofthis section ora special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so thatitis legible to passengers or crew. The UAs fully loaded weighs no more than5lbs (including payload) andis operated without an onboard pilot. As such, there isno ability or place to carry certification and registration documents orto display them onthe UAs. An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the PIC flying the UAs will have immediate access to them, tothe extent they are applicable tothe UAs. The FAA has issued numerous exemptions to this regulation.A representative sample of other exceptions includes Exemption No's: 9565, 9665, 9789, 9789A, 9797, 9797 A, 9816A and 10700. 14 CFR §91.405(a); 407(a)(1); 409(a)(2); 417(a) &(b)- Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eof this part and shall between required inspections, except as provided in paragraph (c)ofthis section, have discrepancies repaired as prescribed in part 43ofthis chapter ..."and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply tothe Applicant.Maintenance will be accomplished bythe PIC pursuant tothe flight manual and operating handbook. Asthe manufacturer does not provide specific maintenance instruction, UAs maintenance will be"on condition" forall aircraft and each aircraft will havea maintenance log. An equivalent level of safety will be achieved because these small UAs are very limited in size, will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAs can land immediately and will be operating from no higher than 400 feet AGL. As provided inthe Manual, the PIC will ensure that the UAsisin proper working order prior to initiating flight, perform required maintenance, and keep alogof any maintenance performed.Page 11 of12 Moreover, the PICisthe person most familiar with the aircraft and best suited to

maintain the aircraft inan airworthy condition to provide the equivalent level of safety. Ifthe PIC encounters a maintenance issue that cannot be addressed, the UAs will be returned tothe manufacturer, ora qualified repair facility where such repairs andjor maintenance canbe performed. Pursuant to14 CFR. PartII,the following summary is provided for publication inthe

Federal Register, should itbe determined that publication is needed. Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H;14 CFR 45.23(b); 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) 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 vehicle (55 lbsor less) for aerial transportation, surveillance, photography and/or aerial filming operations.Approval of exemptions allowing commercial operations of UAs inthe aerial transportation, surveillance, photo and/or film industry will enhance safety by reducing risk. Conventional operations, using jetor piston power aircraft, operate at extremely low altitudes just feet from the target location and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh inthe neighborhood of 4,000 lbs., carrying large amounts ofjetAor other fuel. Such aircraft must flytoand from the aerial location. In contrast, aUAs weighing fewer than 55lbs and powered by batteries eliminates virtually allofthat risk given the reduced mass and lack of combustible fuel carried on board. The UAs is carried tothe launch site. The UAs will carry no passenger(s) or crew and, therefore, will not expose them tothe risks associated with manned aircraft flight operation(s).The operation of small UAs, weighting less than 55 lbs., conducted inthe strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe exemptions requested herein, including exempting the Applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, andina sterile environment and, asa result, arefar safer than conventional operations conducted with turbine Helicopters operating in close proximity tothe ground and people. PrivacyAll flights will occur over private or controlled access property with the property owner's prior knowledge and consent. Filming will beof people who have also consented to being filmed or otherwise have agreed tobeinthe area where filming will take place.Page 12 of12 Ifyou have any questions, or need any additional information, please contact the undersigned at +1(530)409-8139 (cell), orvia email arsenych@me.com. Sincerely yours,**c~~~**E20N, Founder