January	15,	2016

U.S.	Department	of	Transportation

Federal	Aviation	Administration

800	Independence	Avenue,	SW

Washington,	DC	20591

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	

Regulations	from:	14	CFR	61.113{a)	&	(b);	91.7	(a);	91.103;	91.119{c);	91.121;	91.151{a);	91.405{a);	

91.407(a)(1);	91.409	(a)(1)	and	{2};	91.417{a)	&	(b).

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act,	I,	Aaron	Little,	operator	of	an	Unmanned	

Aircraft	System	(UAS),	hereby	apply,	on	behalf	of	Little Media,	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	UAS,	so	long	as	such	operations	are	

conducted	within	and	under	the	conditions	outlined	herein	or as	may	be	established	by	the	FAA	as	required	

by	Section	333.

I	would	like	to	formally	submit	for	an	exemption	from	part	21,	subpart	H;	and	Sections	45.23(b),	91.7(a),	

91.9(b)(2),	91.119,	91.121,	91.151(a),	91.203(a)	and	(b),	91.405(a),	91.407(a)(1),	91.409(a)(2),	and	

91.417(a)	and	(b)	of	Title	14,	Code	of	Federal	Regulations	(14	CFR).	This	proposed	exemption	would	allow	

the	operation	of	unmanned	aircraft	systems	(UAS)	for	the	purpose	of	aerial	videography	and	photography	

real	estate	purposes	and	events.

Applicant:

Aaron	Little

Owner

Little Media

6360	Sierra	Circle

Beaumont,	TX 77708

littlemedia.tx@gmail.com

(409)	748-0122

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera	and	sensors,	would	

operate	in	the	following	manner:

 Aerial photography and/or video for public and/or private use including real estate and other related

professional activities.

 Aerial video and/or photography for public and/or private use including public and private events.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	UAS	under	controlled	

conditions	in	the	NAS	that	would	be	a)	limited,	b)	controlled,	c)	predetermined,	and	d)	will	provide	safety	

enhancements	to	the	already	safe	operations	in	the	industry	presently	using	conventional	aircraft.

Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation	

responsibilities	to	“....establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	

airspace	system.”

As	found	in	Exemption	No.	11138	(Trudeau),	the	FAA	recently	approved	similar	use	of	a	PHANTOM	2	UAS.	

We	will	operate	a	UAS,	the	DJI	Phantom	3	Professional,	Model	W323,	which	is	comprised	of	an	unmanned	

aircraft	(UA	or	Phantom),	an attached	4K	camera	and	a	transportable	ground	station.
The	PHANTOM	3	is	a	quad-copter	with	a	gross	weight	of	2.8	pounds.	It	is	equipped	with	four	rotors	that	are	

driven	by	electric	motors	powered	by	batteries.	The	UA	has	a	maximum	airspeed	of	16	m/s.	It will	be	

operated	over	various	metropolitan	areas,	primarily	around	Beaumont,	TX,	to	augment	real	estate	listing	

videos,	capture	event	aerial	video	and	photography,	and	related	business	operations.

UAS Operating Parameters

We	will	abide	by	the	following	additional	operating	conditions	under	this	exemption,	which	ensures	a	level	of	

safety	at	least	equal	to	existing	rules:

 Operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in

direct line of sight visual observation;

 Obtain permission from the owner/controller of any vessels, vehicles and structures when

operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will

conduct a safety assessment of the risk of operating closer to those objects and determine that it does

not present an undue hazard;

 Operate the UAS for 5-15	minutes per flight;

 Land UAS prior to the manufacturer’s recommended minimum level of battery power;

 Operate UAS during daylight hours only within visual line of sight (VLOS);

 Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly

lands if communication with the remote control is lost;

 Conduct all operations under the flight safety protocols (including posting a warning sign reading:

“Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the operating

documents and will actively analyze flight data and other sources of information to constantly update

and enhance safety protocols;

 Contact respective airports if operations will be within 5 miles to advise them of his estimated flight

time, flight duration, elevation of flight and other pertinent information;

 Always obtain all necessary permissions prior to operation; have procedures in place to abort flights

in the event of safety breaches or potential danger;

 Only operate in safe environments that are strictly controlled, are away from power lines, elevated

lights, airports and densely populated areas (defined by areas depicted in “yellow” on	VFR charts and

through obtaining information regarding congested areas from the local Flight Standards District

Office (FSDO);

 Conduct extensive preflight inspections and protocols, during which safety carries primary

importance (reference PHANTOM Flying Flow Chart and User Manual).

Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists

simulating flights for future	commercial use to gain familiarization with the flight	characteristics and	the UAS’

performance under different temperature and weather conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b),

25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. The PIC will also have accumulated and logged	a minimum of 5 hours as a UAS pilot operating the

same make and model of UAS to be used for operations. In addition to the hour requirements, the PIC will

accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes) prior to any flight.

Specific Exemptions Requested

Given	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	UA,	we	feel	an	exemption	from	

14	CFR	part	21,	Subpart	H	(Airworthiness	Certificates)	and	§	91.203(a)	and	(b)	(Certifications	required),	

subject	to	certain	conditions	and	limitations,	is	warranted	and	meets	the	requirements	for	an	equivalent	level	

of	safety	under	14	CFR	part	11	and	Section	333	of	P.L.	112-95	(Section	333).

We	request	an	exemption	from	§	45.23	Marking	of	the	aircraft	because	the	UA	will	not	have	a	cabin,	cockpit

or pilot	station	on	which	to	mark	certain	words	or	phrases.	Further,	the	two-inch	lettering	is	difficult	to	place	

on	such	a	small	aircraft	with	dimensions	smaller	than	the	minimal	lettering	requirement.	Regardless	of	this,	
we can mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as

required	by	§	45.29(f)	so	that	anyone	will	see	the	markings.

We	request	an	exemption	from	§	91.7(a)	which	prohibits	the	operation	of	an	aircraft	without	an	

airworthiness	certificate,	since	there	is	currently	no	certificate	applicable	to	our	operation,	this	regulation	is	

inapplicable.

We	request	an	exemption	from	§§ 91.405(a),	91.407(a)(1),	91.409(a)(2)	and	91.417(a)	and	(b)	Maintenance	

inspections	since	they	only	apply	to	aircraft	with	an	airworthiness	certificate.	However,	as	a	safety	precaution	

we	will	perform	a	preflight	inspection	of	the	UAS	before	each	flight	as	outlined	in	the	manufacturers

operating	documents.

We	request	an	exemption	from	§	91.9(b)(2)	which	requires	an	aircraft	flight	manual	in	the	aircraft,	however	

since	there	are	no	pilots	or	passengers	on	board	the	aircraft	and	given	its	size,	this	regulation	is	inapplicable.	

We	believe	an	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	safety/flight	manual	with	the	UAS	

ground	station.

We	request	an	exemption	from	§	91.119	which	prescribes	safe	altitudes	for	the	operation	of	civil	aircraft,	but	

it	allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	We	will	not	operate	our	UAS	

above	the	altitude	of	300	feet	above	ground	level	(AGL)	and	will	also	only operate in	safe	areas	away	from	the	

public	and	traffic,	thus	“providing	a	level	of	safety	at	least	equivalent	to	or	below	those	in	relation	to	

minimum	safe	altitudes.”	Given	the	size,	weight,	maneuverability,	and	speed	of	the	UAS,	an	equivalent	or	

higher	level	of	safety	will	be	achieved.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes

electronic GPS with a barometric sensor.

We	request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100%

electric and two low battery alerts are issued - per the operating documents, the UAV will be landed at the

first alert. Also, our flights will last only 5-15	minutes each, and the UAS has an automated function, which

results in immediate landing when a	low battery is detected. The PIC will not begin a flight unless

(considering wind and forecast weather conditions) there is enough power to fly to the first point of intended

landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

Public Interest

Aerial photography and videography for real estate and events are proven strategies to enhance marketing

efforts and increase business success. The industry is not new. However, until recently it was conducted

through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting

this exemption I would be able to provide affordable services.

Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel when

compared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to the

environment economic growth by providing information to companies and the public looking to relocate or

build in the metro areas we service. Public and private events serviced by our business enhance vibrancy and

add culture to the community and its citizens.

Summary

We will comply with all of the following conditions and limitations should this exemption be provided:

1. Operations will be limited to the following aircraft described in the operating documents, which is a

quad-rotor aircraft weighing 2.8 pounds: Phantom 3 Unmanned Aircraft System.

2. The UA will not be flown at an indicated airspeed exceeding 50 knots.

3. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), All

altitudes reported to ATC must be in feet AGL.

4. The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times.
5. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of

sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times.

The PIC will be designated before the flight and will not transfer his or her designation for the

duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the

operating documents.

6. The operating documents will be accessible during UAS operations and made available to the

Administrator upon request. Any revisions to the operating documents will be presented to the

Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated

until the necessary maintenance has been performed and the UAS is found to be in a condition for

safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance

and alterations will be properly documented in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts

the functional test flight will make an entry in the aircraft records.

9. The pre-flight inspection section in the operating documents will account for all discrepancies, i.e.

inoperable components, items, or equipment, not already covered in the relevant sections of the

operating documents.

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement,

inspection, and life limit requirements.

11. We will carry out maintenance, inspections, and record keeping requirements, in accordance with

the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft

records, including total flight hours, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action taken against

discrepancies discovered between inspections.

14. UAS operations will be conducted by a PIC possessing at least a	private pilot certificate and at least a

current third-class medical certificate. The PIC will also meet the flight review requirements specified

in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15. Prior to operations conducted for the purpose of aerial videography/photography and for real estate

listing videos and public and private events and similar operations, the PIC will have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

16. Prior to operations conducted for the purpose of aerial videography/photography and for real estate

listing videos and public and private events and similar operations, the PIC will have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot

operating the make and model of the UAS to be used in operations. The PIC will accomplish 3 takeoffs and landings in the preceding 90 days.

17. The PIC will not operate the UAS for the purpose of aerial videography/photography and for real

estate listing videos and public and private events and similar operations, unless the PIC has

demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate

the UAS in a manner consistent with the operating documents, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

18. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be

conducted under visual meteorological conditions (VMC).

19. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current

FAA-published aeronautical chart.

20. The UA 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.

21. If a UA loses communications or loses its GPS signal, it will return to a predetermined location within

the planned operating area and land or be recovered in accordance with the operating documents.

22. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with

the operating documents.
23. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is

enough power to fly at normal cruising speed to the intended landing point and land the UA with

30% battery power remaining.

24. We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA)

prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72

hours in advance, but not less than 48 hours prior to the operation.

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA

will comply with the Federal Communications Commission (FCC) or other appropriate government

oversight agency requirements.

26. The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground

Control Station of the UAS any time the UAS is operating. These documents will be made available to

the Administrator or any law enforcement official upon request.

27. The UA will remain clear and yield the right of way to all manned aviation operations and activities at

all times.

28. The UAS will not be operated by the PIC from any moving device or vehicle.

29. The UA will not be operated over congested or densely populated areas.

30. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels,

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA and/or debris in the event of an accident. We will ensure that nonparticipating persons

remain under such protection. If a situation arises where nonparticipating persons leave

such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of

such vessels, vehicles or structures has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it does not

present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an

undue hazard to those persons per § 91.119(a).

31. All operations will be conducted over private or controlled---access property with permission from

the land owner/controller or authorized representative. Permission from land owner/controller or

authorized representative will be obtained for each flight to be conducted.

32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration

Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If you have questions or need additional information, please contact me at littlemedia.tx@gmail.com or (409)

748-0122.

Thank you,

Aaron	Little

Owner

Little Media