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/orvideo 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.	Itwill	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.
**UA S 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 of1000 feet from the controller to aid in directline ofsightvisual observation;

 Obtain permission from the owner/controller ofanyvessels, vehicles and structures when operations may be conducted closer than 500 feetto any such vessels, vehicles or structures; we will conduct a safety assessment ofthe risk ofoperating 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 ofbattery power;

 Operate UAS during daylighthours onlywithin visual line ofsight (VLOS);

 Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands ifcommunication 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 ofinformation to constantly update and enhance safety protocols;

 Contact respective airports ifoperations will be within 5 miles to advise them ofhis estimated flight time, flight duration, elevation offlight and other pertinent information;

 Always obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event ofsafety 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” onVFR 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 andthe UAS’ performance under differenttemperature and weather conditions. Any PIC operating our UAS will have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including atleast 10 hours logged as a UAS pilotwith a multi

rotor UAS. The PIC will also have accumulated and logged a minimum of5 hours as a UAS pilot operating the
same make and model ofUAS 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.
**S pecific 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 f light	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 UAVwill be landed atthe 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 notbegin a flight unless (considering wind and forecastweather conditions) there is enough power to flyto the first point ofintended landing and, assuming normal cruising speed, land the UAwith 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 itwas conducted through the use ofcostly 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 threatto the public given its small size and lack ofcombustible fuel when compared to larger manned aircraft. Additionally, the operation ofour 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 complywith all ofthe 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 aircraftweighing 2.8 pounds: Phantom 3 Unmanned Aircraft System. 2. The UA will notbe flown at an indicated airspeed exceeding 50 knots. 3. The UA will be operated at an altitude ofno more than 400 feet above ground level (AGL), All altitudes reported to ATC mustbe in feetAGL. 4. The UA will be operated within visual line ofsight (VLOS) ofthe 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) ofthe 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 nottransfer his or her designation for the duration ofthe flight. The PIC will ensure thatthe 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 inspectthe UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the UAS will notbe 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 affectthe UAS operation or flight characteristics, e.g. replacement ofa flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flightwill 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 ofthe operating documents. 10. We will followthe 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 flighthours, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 12. Each UAS operated will complywith all manufacturer Safety Bulletins. 13. An authorized person will make an entry in the aircraft record ofthe 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 atleast a currentthird

-class medical certificate. The PIC will also meetthe 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 ofaerial videography/photography and for real estate listingvideos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), a minimum of25 hours oftotal time as a UAS rotorcraft pilot including atleast 10 hours logged as a UAS pilotwith a multi

-rotor UAS. 16. Prior to operations conducted for the purpose ofaerial videography/photography and for real estate listingvideos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), a minimum of5 hours as UAS pilot operating the make and model ofthe UAS to be used in operations. The PIC will accomplish 3 take

offs and landings in the preceding 90 days. 17. The PIC will not operate the UAS for the purpose ofaerial 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 consistentwith 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistentwith the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 18. UAS operations will notbe conducted during night, as defined in 14 CFR 1.1. All operations will be conducted undervisual meteorological conditions (VMC). 19. The UA will not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart. 20. The UA will notbe operated less than 500 feetbelow or less than 2,000 feethorizontally from a cloud
or when visibility is less than 3 statute miles from the PIC. 21. Ifa UA loses communications or loses its GPS signal, itwill 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 ofunpredicted obstacles or emergencies in accordance with the operating documents.23. The PIC will notbegin a flight unless (considering wind and forecastweather 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 ofWaiver orAuthorization (COA) prior to conducting any operations, and also request a Notice to Air

-man (NOTAM) not more than 72 hours in advance, but notless than 48 hours prior to the operation. 25. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA will complywith 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 atthe Ground Control Station ofthe UAS anytime 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 ofway to all manned aviation operations and activities at all times. 28. The UAS will notbe operated by the PIC from any moving device orvehicle. 29. The UA will notbe 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 presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. We will ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe 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 ofthe risk ofoperating 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 propertywith permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flightto be conducted. 32. Any incident, accident, or flight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined bythe 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

. Ifyou have questions or need additional information, please contact me atlittlemedia.tx@gmail.com or (409) 748

-0122

. Thankyou, Aaron	Little Owner Little Media