1 Brian Kulpa Brian Kulpa Photography LLC 3924 Kentwood Ct. Reno, NV 89503

(413) 464

- 1966 brian@briankulpaphotography.com

December 4, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590
RE: Amendments to Grant of Exemption No. 12446 Regulatory Docket No. FAA

− 2015

− 0820 Dear Sir or Madam,

On August 12, 2015 the Federal Aviation Administration (“FAA”) granted an exemption from certain provisi ons of the Federal Aviation Regulations (“FAR”) pursuant to Section 333 of Public Law 112

- 95 to petitioner Brian Kulpa Photography permitting operation of a DJI Inspire 1 small unmanned aerial system (“sUAS”) for the purposes of conducting aerial photograp hy, videography, surveying, cinematography, inspections and search and rescue.

Please see Grant of Exemption No. 12446 (the “Grant of Exemption”) and Brian Kulpa Photography’s petition for exemption, docket no. FAA

- 2015

- 0820, the terms of both are attached separately from this amendment. Brian Kulpa Photography has submitted all necessary paperwork to the FAA in regards of Aircraft Registration (AC Form 8050

- 1) and Aircraft Bill of Sale (AC Form 8050

- 2) as Brian Kulpa Photography LLC, which was formed on
Oc tober 8, 2015, all documentation, including the Articles of Organization,2 are on file with the FAA. Brian Kulpa Photography now submits this request to amend the Grant of Exemption as follows:

A) To expand the scope of the Grant of E xemption to permit operation of
covered small

- unmanned aerial systems (“sUAS”) in gathering aerial photography and videography for television/newsgathering, closed set motion picture filming, real estate, and golf courses.

. Additional Scope of Use

Brian Kulpa Photography requests amendment of the Grant of Exemption to permit use of covered sUAS for the purposes of photography and videography in the categories of television/ newsgathering, closed set motion picture filmin g, real estate, and golf cours es . The public benefits of a grant of exemption for these uses are evident from the Grant of Exemption. Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 500 feet AGL. sUAS on the other hand are best when flown
bet ween 50 and 275 feet AGL and in fact the best video quality is 50 to 175 feet. A manned helicopter could cause very serious damage to persons or property on the ground in a system failure, most notably the pilots and passengers inside a manned helicopter. A sUAS on the other hand weighing in at approximately seven pounds would not be nearly as hazardous. A
standard helicopter is normally larger than an automobile whereas the s UAS
is drastically smaller, in t his case weighing less than ten pounds. It is substantially safer for the public to have a sUAS accomplish the job of aerial photography and videography than a manned helicopter just based on size
alone. Further, there has been no change in the conditions and reasons relative to the public interest and safety that were the basis for granting the3 original exemption.

For the purposes of television/ newsgathering , a sUAS may be an exceptional tool for journalists

. It will provide a different perspective of what is being covered in a particular story to educating the public on unmanned aerial systems . This would allow the j ournalist to provide enhancing , accurate distribution of newsworthy and relevant info rmation to all citizens, while educating them about unmanned aerial systems in the process

. The public looks to news outlets as its source of information about events happening in the region, nationally, and globally. By using sUAS to achieve a different perspective, much more safely than a manned he licopter that is carrying a
fuel load , t his would allow the citizens to engage in the topic being covered by the journalist in a different perspective than otherwise notably observed from the ground.

This also ties into closed set motion picture filming, real estate, and golf course aerial photography and videography. It is much safer for all persons and property involved on a closed set motion picture filming , real estate, and golf course to be using a sUAS instead of a helicopter because a fuel load is not being carried, instead a battery pack is used as the sUAS power source. When being used in in these situations , you have to factor in the terrain in
which you are filming . The use of a sUAS would be able to maneuver much
safer to the ground based on size alone compared to the size of a helicopter. The use of sUAS benefits the public by providing a safer environment and educational platform when gathering aerial photography and videography
for television / newsgathering, closed set m otion picture filming, real estate, and golf courses.4 I, Brian Kulpa, respectfully submit this amendment to the Grant of Exemption No. 12446, previously granted to Brian Kulpa Photography

.

Brian Kulpa Brian Kulpa Photography LLC 3924 Kentwood Ct. Reno, NV 89503 (413) 464

- 1966 brian@briankulpaphotography.com