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Monday, October 26, 2015 U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey

Ave, SE Washington, DC 20590 Petitioners Contact Information: Petitioner: Mark Klatman Epic Media, Inc. 2755 E. Oakland Park Blvd. #102 Fort Lauderdale, Florida 33306 Phone No: 954

- 790

- 6790 Email: mark@epicmediausa.com Petitioner is seeking an exemption from the following rules: 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R 45.11; 14 C.F.R. 45.27; 14 C.F.R. 4 5.29; 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R 61.113(a); 14 C.F.R 61.315(a); 14 C.F.R 91.7(a); 14 C.F.R 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91 .119 (c); 14 C.F.R.91.121, 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially small unmanned aircraft s ys tems (UAs) (6.5 lbs. or less). Unmanned Aircraft System Petitioner plans to operate a UAS, the DJ I PHANTOM 2, which is comprised of an unmanned aircraft and a transportable ground station. The DJ I PHANTOM 2 is a quad

- copter with a maximum gross weight of approximately 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The DJ I PHANTOM 2 has a maximum airspeed of 30 knots. Please see DJ I PHANTOM 2 Manual attached hereto and incorporated as Exhibit “A”. Petitioner is a videographer and will be using the **aerial photography and /or video for**  **public and/or private use for marketing of residential and commercial real estate, inspections, surveys, television production for both open and closed sets, and social**  **events.** Petitioner will only

operate the UAS in a safe environment that i s strictly controlled and away from power lines, airports and heavil y populated areas. Petitioner will conduct extensive preflight inspections and protocols to ensure that thePage 2 of 5

DJI PHANTOM 2 is operating effectivel y and safely. Flights will be at altitudes of no more than 400 feet agl, and at speeds less than 20 knots. Despite, the 400 ft agl limit most flights will take place at an altitude of no more than 100 foot agl. Flights will be operated within line of sight of a Pilot in Charge (PIC) and Visual Obs erver (VO)

. The requested exemption will permit the operation of the DJ I PHANTOM 2. The DJ I PHANTOM 2 is a small, unmanned multi

-rotor aircraft, weighing 2.9lbs. inclusive of batteries, the propeller guard and technical payload. The rotorcraft can operate at a speed up to 29 knots, but Epic Media, Inc. will limit the speed to no more than 20 knots. The F AA has previousl y granted Exemption No. 11138, allowing commercial flight of a member of the DJ I Phantom 2 Family, the Phantom 2 Visions + Exemption 11138 is attached hereto and incorporated as Exhibit “B”. The Phantom 2 will have the following specifications: Airframe: DJ I Phantom 2 Flight Control S ys tem: Naza

– M V2, which includes the main controller (MC) inter nal measurement unit (IMU) with built

- in internal sensor, barometric altimeter, whi ch measures attitude and altitude, compass, GPS, and radio receiver (Rx). Transmitter (Tx): 2.4 GHz remote controller Receiver (Rx): Internal to DJIPhantom 2 Data Link: 2.4G Data Link Video Link: DJ I AVL 5

. 8 Gimbal: H4

- 3 D Zenmuse Gimbal for GoPro Hero Camera: Go Pro Hero 4 Black Batteries: 3S LiPo, 5200

- mAh, 11.1V iOSD: DJIiOSD mini, which allows live telemetry to be displayed on the video monitor, including the battery

level and altitude. Training The PIC will be trained in operation of UAS generally and receive up to date information on the UAS to be operated pursuant to this grant. The PIC has received DJI PHANTOMPage 3 of 5

2 specific training and will continue to keep up to date training on the DJ I PHANTOM 2 to ensure effi ciency

on the platform. The PIC’s experience includes over 250 hours of flying time with the Phantom 2

. The minimum flight crew for each operation will consist of the UA , PIC , and VO. The PIC will have completed UA

- specific training provided by the manuf

acturer prior to commercial operations. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria and demonstrates the ability to safel y operate the UA in a manner consistent with how the UA will be operated under this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR §61.51(b). A record of the PIC training will be documented and made available upon request by the Administrator. Training operations will only

be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions, and will not be permitted to operate the camera or other instruments. Petitioner states that the intended use of the UAS would be for **a erial photography**  **and/or video for public and/or private use for marketing of residential and**  **commercial real estate, inspections, surveys, television production for both open and closed sets, and social events.**  This ty pe of data collection has been done by manned aircraft or b y individuals on the ground. However, there is an enhanced safety and a reduction in environmental impact that is achieved b y using a UAS. Safety The DJ I PHANTOM 2 will be flown in airspace under 400 feet above ground level (“AGL”) and under controlled conditi ons in rural areas. Epic Media will avoid congested and densel y populated areas and will work with local Flight Standard District Offices to determine safe areas to fly in. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no undue hazards are present. Prior to departing for an operation, the flight crew wil l briefly turn on the DJI PHANTOM 2 to ensure that every thing is connected and that the DJ I PHANTOM 2 is in operational condition. Upon arrival at a location for filming or photography, the flight crew will conduct an aerial and ground preflight inspection. This inspection is listed in Appendix D to the DJI Phantom 2.Page 4 of 5

If the radio control link is broken during flight, the autopilo t system will recognize this broken control link and cause the DJ I PHANTOM 2 to automatically return to the home area as recorded by the GPS instrumentation. The flight crew will conduct a phys ical inspection of the aircraft. At any time during the flight, should the aircraft lose connection with the remote control, the flight control system failsafe will be activated automatically, and the aircraft will to return to the previously

- set home area and land, in order to reduce injuries or damage. If any of the following situations occur, the aircraft will not receive a signal, and enter into this failsafe mode: 1. The remote control is powered off. 2. The aircraft has flown out of the effective communication range of the remote control, which is no greater than 1, 000 meters (3,280 feet). 3. There is an obstacle obstructing the signal between the remote control and the aircraft, essentiall y reducing the distance the signal can travel 4. or there is interference causing a signal problem with the remote control. For further information regarding the DJ I P HANTOM 2 ’ s failsafe functions, please refer to Exhibit “A” , the DJ I PHANTOM 2 User Manual, Section 6.4, beginning on page 25 of that document

. The DJ I P HANTOM 2 also has “no fl y zones” programmed into it, which will prevent flights in restricted zones. Although Epic Media, Inc. will take every precaution to avoid flying in airspace other than class G airspace, the preprogrammed “no fl y zones” will add an additional level of safety to operations. For further information reg arding the DJ I ’ s PHANTOM 2 “no fl y z ones,” please refer to Exhibit “A” , Section 6.7 of the DJ I User Manual, beginning on page 28 of that document

. Other than this automated feature of the DJ I PHANTOM 2, the PIC will always fl y the PHANTOM 2 manuall y. The PIC and VO have tested the DJ I PHANTOM 2 in a variety of weather conditions

. The PIC and VO will not fly the DJ I PHANTOM 2 in heavy rainstorms, or high winds due to decreased visibility and the potential for water damage to the DJI PHANTOM 2. The PIC and V O have also practiced emergency bailout procedures by having the DJI PHANTOM 2 return to home. In the event of an emergency, the PIC will release the joysticks. This will make the DJ I PHANTOM 2 automatically hover in place and maintain its position and altitude, and the PIC and VO can determine if and when it is safe for the DJ I PHANTOM 2 to return to the home location. During flights, the PI C and the VO will be standing next to each other, in oral communication at all times at the ground station. The VO will observe the telemetry data on the laptop and will monitor the images from the camera from the laptop. The VO will direct the PIC if he wishes to capture a different angle on the camera. The Go Pro Hero 4 Black camera will be filming or taking still images at intervals during the entirety of thePage 5 of 5

flight and is not controlled independentl y from the ground station, other than by the movement of the DJ I PHANTOM 2 controller. Flights will be limited to 15 minutes, which is approximately 75% of the total battery life of the DJ I PHANTOM 2.