### HiRez Productions, LLC

1101 S. State Street Apt 2202 Chicago, IL 60605 P: 312.735.0768 E: Michael@HiRezProductions.com W: HiRezProductions.com

December 16th, 2015
**U.S. Department of Transportation Docket Management System**  1200 New Jersey

Avenue, SE W ashington, DC 20590 RE: Request for Exemption Per PL 112

- 95 § 333 from 14 CFR Part 21, 14 CFR 45.23 (b), 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 203 (a) & (b), 14 C FR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.417(a) and (b)

To Wh om It May Concern,
This letter will serve as a request for an exemption of the above sections of title 14 CFR for HiRez Productions, LLC, henceforth referred to as the “Petitioner,” for the purpose of conducting commercial aerial photography, videography, home inspections, and survey operations using a sm all Unm anned Aircraft System (sUAS) in FAA controlled airspace. As described herein, the Petitioner has staff who are experienced in the op eration of UAS, including but not limited to use of multi

- rotor sUAS, flying multicopters of varying sizes under 55 pounds using both Visual Line Of Sight (VLOS) and on board camera controls. The following petition provides all of the necessary informatio n to justify an exemption from the above listed Federal Aviation Regulations.

**The Unmanned A ircraft System**  The Petitioner will be operating a DJI Phantom II. The Petitioner may add additional airframes to their inventory as required from the DJI or other lines. The Petitioner will operate the airframe within its design parameters. The sUAS has built in functionality that can limit the height it flies above the ground and restrict sUAS from flying in class B,C, and D airspace. The aircraft also comes preinstalled with the ability to automatically return to the pilot in control and land if any of the previous restrictions are violated, or if the connection to the wireless controller is lost. The sUAS weighs 2935 grams (just under 6 pounds) while carrying all necessary batteries and cameras. It also has a max speed of 22 meters per second (just under 43 knots) that can be limited prior to takeoff. **The Unmanned A ircraft PIC**  The company senior operat or and initial PIC Michael Himes is an experienced operator. Mr. Himes has over 100 hours of sUAS in recreational flights. HiRez Productions, LLC, will keeplogged hours of training events and duration of flight operations. New PICs will have a minimum

of 5 actual flight hours (15 Flights ) before being allowed to operate sUAVs.

**sU AS Operation Overview**  The sUAS will be operated to provide aerial photography, videography, and survey services to the public sector, particularly for the purposes of real estate, weddings, events, property inspection, and property surveys. Prior to the operation, flight restrictions will be programmed into the sUAS to prevent it from flying more than 400 feet above ground level. Before takeoff, the operator and observer will review the pre

-flight checklist and survey the area to determine if weather/cloud conditions are suitable for flight and what the emergency landing sites would be. Once the operations are com plete, the sUAS will be inspected to determine if any maintenance will be needed before the next operation. Compared to traditional flights using manned aircraft, flights using sUAS are much less dangerous and therefore would not adversely affect safety :

 The nature of these flights will restrict the use of the sUAS to a small area where all nearby persons can be aware of ongoing flight

 The sUAS carries no explosive materi als or combustible liquid fuel

 The light weight of the sUAS would cause minimal damage in the event of an airborne failure, especially when compared to traditional manned aircraft with airworthiness certificates

 The small size of the sUAS would allow for a ll operations to be conducted within a clearly defined area, including takeoffs and landings.
All flights by the PIC will begin and remain outside of a 5 nautical miles radius of any airport having an operational control tower, 3 nautical miles from an airport with a published instrument flight procedure but not an operational tower, 2 nautical miles from an airport without a published instrument flight procedure or an operational tower and 2 nautical miles from a heliport with a published instrument fli ght procedure. The sUAS has a mandatory, built

- in functionality to restrict the aircraft from flying within this radius and will automatically land if it inadvertently violates this restriction. Any and all precautions will be taken by the PIC and the acco mp anying observer to prevent midair collisions with objects and other aircraft, even outside the 5 nautical mi le radius of airports.

All planned operations utilizing the sUAS will be completed safely. W ith the combination of the preflight safety risk assessments previously discussed and the inherently reduced risk of fly ing a sUAS compared to a traditional manned aircraft, the PIC will be able to provide a level of safety greater than the traditional method of performing aerial based photography, video graphy, and survey operations. **Benefit to Public Interest** The services provided by the Petitioner would be a great benefit to the public as a whole. Granting this exemption would reduce the need for traditional forms of aerial photography, videography, inspections, and surveys which, as previously discussed, are mu ch more dangerous than operations performed by sUAS. The cost of services of sUAS operations is also significantly lower than traditional aerial photography flights, making these services available to smaller businesses or individuals that otherwise may not be able to afford them. This in turn, allows businesses to better serve their clients, increasing the public benefit as a whole.**Conclusion** All commercial sUAS flights by the Petitioner shall satisfy the criteria provided in Section 333 of the Reform Act of 2012, including: size, weight, speed, flight within VLOS, distance from PIC, distance from airports, operation capabilities, maintaining safety, and the benefit to the public. These qualifications more than justify granting the Petitioner, HiR ez Productions, LLC, with an exemption to the stated sections of title 14 CFR. The requests of this Petition are similar to those of Marcus D. Melhus, Ralph J. Apel, Saratoga Aerial and Video, and Cornerstone Technology Services, all of whom have receiv ed Section 333 exemptions for use of comparable aircraft for similar operations. Thank you for your time and consideration. Sincerely,

Michael C. Himes Founder/President HiRez Productions, LLC