July 1, 2015

U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room wi2-i40 1200 NewJersey Avenue, SE., Washington, DC 20590

REQUEST FOR FAA UA EXEMPTION JeffreyTaylor dba BlissfuFilms P.O. Box 621645 Oviedo, Florida 32762

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations To Whom It May Concern:
Pursuant to Section 333 of the FAA Modernization and ReformAct of 2012 (the "Reform Act") and 14 C.F.R. Part 11, JeffreyTaylor dba Blissfulfilms seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described UnmannedAerial System called in this application the ME System, which includes an UnmannedAircraft (UA) and ground station-based equipment and crew: THE UNMANNEDAIRCRAFT (UA): 

### ['?] A lightweight (20 lb gross weight with all on-board equipment), manufactured by Horizon Hobby Blade 350 QXAP Combo, that includes the following equipment in flight; 

### [)f] An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller; 

### ['1?] An on-board camera capable ofcapturing imagery in the form offull color, high definition still photos and video; 

### ()f] An on-board telemetry system thatdeliversflight data from the on-board flight computerto the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; 

### {!IA 2.4GHz on-board radio transmitter that transmits live video from the on-board camera plus all the flight datafrom the telemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM: 

## 00 A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAwhile in the air; 

## 00 A 2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight;**[~** A radio receiver receiving livevideo and flight datafrom the on-board camera and computer projects it all together onto a screen forthe PIC to view during flight; 

### ['1?.] A Visual Observer (VO) is a person who provides a second pair ofeyesto visually track the UAwhile in flight.

### The requested exemption would support an application for a commercial Certificate of Authorization to usethe above described ME System to support Production ofpromotional materials (video and/or still images)for Real Estate sales Production of promotional materials, (video and/orstill images) forTravel and Tourism industriesProduction of promotional materials, (video and/orstill images) for commercial businesses,Photography and videography of social events, such asweddings neveroperating overpersons not directly involved with the ME system. The UA, powered by batteries, is smaller, lighter and more maneuverablethan larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death orserious bodily injury. With a small payload and maximum flight time ofonly 18 minutes, this is offers little or no riskto national security.
Low level oblique photos and video from several angles are far more effective than groundbased imageryfordisplaying the characteristics of large, complex properties with several buildings and largetrees. The alternative could be to charter a full-sized helicopterforthis purpose, which has proven more costlythan many potential clients are ableto afford. The benefits of reduced cost and improved qualityof presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property. Additionally, we requestthat we be allowed to use oursystem to benefitfirst responders nearby who might require assistance, including fire fighters, the police, the sheriff, et at., while remaining subjectto all limitations cited in this application aswedoso. The ME System will be operated in thefield with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14"Operational Requirements for UAS" and with thefollowing Restrictions: a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400ftAGL, at an airspeed of no morethan 50 knots and nofurtherthan 3/4 NMfrom the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate byvoice at all times during a flight operation; d) Operations will be restricted to flights over property with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a mannerconsistent with 14CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilotwith a similar UAtype; f) All required permits will be obtained from state and local government priorto operation; g) The ME System will not be operated overdensely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assemblyof people; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will notbe operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk beforethe first flight at each new location; n) No flight may be made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UAis in a condition safe forflight (seeAppendixA).The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.
We submitthat the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safetythan manned aircraft performing the same mission.
The name and contact information ofthe applicant are: Jeffrey Taylor dba Blissfulfilms 407-766-9381 jefft7@gmail.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21

.................................Addendum Page 1

- 14 CFR 91.203

.................................Addendum Page 1

- 14 CFR 45.23, 45.29

..........................Addendum Page 2

- 14 CFR 91.9

....................................Addendum Page 2

- 14 CFR 61.113, 61.133

.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91 .121..

............Addendum Page 3

- 14 CFR 91.151

.................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417)

......Addendum Page 3

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1
We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please contact us at anytime if you require additional information or clarification. We look forward to working with your office.

# SinceJ~ 

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# ajv II 

# l;f £eyTaylor dba Blissfulfilms Addendum containing Exemption Requests and Equivalent Level of SafetyAppendixA- Flight Manual's Appendix 8 - Owner's Manual for UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY JeffreyTaylor dba Blissfulfilms requests an exemption from thefollowing regulations as well as any additional regulations that maytechnically applyto the operation ofthe ME System:
14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishesthe procedures forthe issuance of an airworthiness certificate. While the FAA continuesto workto develop airworthiness standardsfor UnmannedAerial Systems, we request an experimental certificate be issued forthe ME System under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and otheroperations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate majordesign changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expectthat an experimental certificate would permit our commercial purpose as well. The aircraft will notcarry persons or property, will not carry fuel, and will only fly understrict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose thatthe UAwill be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.
Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.
14 CFR 91.203(a) 

### & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, with the registration numberassigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) providesthatthe airworthiness certificate be "displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew." At a maximum gross weight of 6.5 pounds, the UAis too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91 .203, we propose that documents deemed appropriate forthis aircraft by the FAAwill be co-located with the crew at the ground control station and available for inspection upon request. In orderto identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: 4105 Fieldstone Rd, Champaign, Illinois 61822 Models: Blade 350 QXAP Combo
14CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least3 inches high. Additionally, the aircraft mustdisplaythe word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UAdoes not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration numberassigned to it by the FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, wherethe PIC, VO and others in the vicinity ofthe aircraft while it is preparing for launch will be ableto see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and choosesto investigate its point of origin.
14CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available tothe crew during flight operations.
To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual (AppendixA) must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation providesthat no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. Our proposed operations require thatthe PIC musteither
1 . Hold a Sport Pilot Certificate issued bythe FAA, and have logged 25 hours offlight experience in this type of UA, or
2. Meetthe requirements of8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA

### Private Pilot written examination." Since there are currently no means available forthe pilot of a UAS to gain the experience in an equivalent category and class in orderto applyfor a commercial pilot's license, we propose to generate an equivalent level ofsafety by requiring our pilotsto complete, at a minimum, FAAcommercial pilot ground instruction and passthe FAA Commercial Pilot written examination in addition AppendixA to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meetthe intent of 61

..113 Subparagraph (b) even though the intent ofthis application isto conduct a business.
14CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flighttests The regulation states that "No person may operate a civil aircraftthat is being used for flight instruction unless that aircraft hasfully functioning dual controls." The ME System ground-based control station consists of a small hand-held radio transmitter and while itdoes not offer a second set of "controls", both the student and instructor can, and will, operate the single set ofcontrols simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meetsthe intent 91.109 and provides an equivalent level ofsafety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation states that oversparsely populated areasthe aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, orstructure. Sincethe aircraftwill be operating at a maximum of400 feetAGL, we cannot comply with this requirement.
In orderto provide an equivalent level of safety we will onlyfly overprivate propertywith a size ofat leasttwo acreswiththe permission ofthe ownerofthe propertyflown over. The aircraftwill not be operated overcongested areas orover anyopen air assembly of persons. The property ownerwill be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraft will be operated at a lowaltitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
14CFR 91.121 Altimetersettings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft.
The UAwill alwaysfly below 400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point istransmitted via radio from the UAon-board computerto the display screen held bythe PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation providesthat no person may begin a flight in an airplane underday-VFR conditions unless there is enough fuel to fly to the first pointof intended landing and to fly after

### thatfor at least30 minutes. We feel the intention ofthis paragraph isto provide an energy reserve as a safety bufferfor delaysto landing. The UAis battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 314 NM from the point of intended landing, a full battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy".
14CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation providesthat the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91 .409 require thatthe aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.
It is our intention thatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure that the aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repair facility. The PIC will documentwork performed in accordance'with 91.417. We feel that dueto the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UAmaximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslyto the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We proposethat the minimum medical requirements forthe PIC and VO be vision corrected to 20/20 and avalid, state issued driver's license. The 20/20vision requirement will ensurethatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified tooperate a much largervehicle.

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I APPENDIXA- FLIGHT MANUAL FLIGHT RESTRICTIONS a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations must occur in FAAClass G airspace at no more than 400'AGL, at an airspeed of no more than 50 knots and nofurtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operationswill be restricted to flights 

### overproperty with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a mannerconsistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilot with a similar UAtype; f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not be operated 

### overdensely populated areas; h) The ME System will not be operated at airshows; i) The ME System will not be operated 

### overany open-air assembly of people; 

### j} The ME System will not be operated 

### overheavily trafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will briefthe VO and property ownerabout the operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe for flight. PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted ifnecessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. CG02 app connected to the aircraft. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV backto the PIC.