513 James Ridge Lane Stockbridge, Ga. 30281

November 24

, 20 15 U.S. Department of Tran spo rtation Docket Management System 1200 New Jersey Ave., SE Washington, D

. C. 20590

Re: Petition of Focus

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- Video, LLC for Exemption from Certain Federal Aviation Regulations to Operate Unmanned Aircraft Syst ems Pursuant to Section 333 of the FAA Modernization and Reform Act

Dear Sir or Madam:

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. part 11, Focus

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- Video, LLC hereby petitions the Federal Aviation Administration ("FAA") for exemption from 14 C.F

. R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 6 1.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417( a) and (b), and any other rules the FAA deems necessary, to en ab le Focus

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- Video, LLC to operate unmanned aircraft systems ("UAS") for aerial photography and video . Specifically, Focus

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- Video, LLC seeks to operate UAS for Aerial Photography, Video graphy and other commercial production, using the DJI Phantom 3. Becau se this petition is similar in all material respects to previou s ly

- granted Section 333 petitions, Focus

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- Video, LLC request s expedited approval pursuant to the FAA's summary grant process.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS Focus

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- Video, LLC , a solely own corporation located in Stoc k bridge, GA. Focus

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- Video, LLC provides wedding and event photography and videography services

. Focus

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- Video, LLC was formed in 2003 by Bernard McRae, 513 James Ridge Lane, Stockbridge, Ga. Focus

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- Video, LLC st rive s to provide wedding and event photography and videography services to the Atlanta and surrounding areas to the specific communities served.



### II. THE UAS Focus

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- Video, LLC requests an exemption to operate the DJI Phantom 3 well below 55 pounds including payload. Through the Section 333 exemption process, the FAA has authorized use of all UAS for which exemption is requested herein.


### III. REQUEST FOR SUMMARY GRANT Because this petition is similar in material respects to previous petitions the FAA has granted, Focus

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- Video, LLC requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited summary grant process. Specifically, the public interest and safety benefits

.

### IV. APPLICANT INFORMATION The name and contact information of the applicant is: Bern ard McRae President/ Owner Focus

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- Video, LLC 513 James Ridge Lane Stockbridge, Ga 30281 Phone: 770

- 957

- 4299 Regulations from which exemption is requested: See Exemption No. 11274A to United Services A utomobile Association, Regulatory Docket No. FAA

2014

- 0796 (authorizing use of the DJI Phantom 3



### V. OPERATING PARAMETERS Focus

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- Video, LLC will adhere to the following operating parameters when operating UAS pursuant to a grant of the requested exemption: 1. Operations will be conducted using the DJI Pha ntom 3 2. The UAS will not be operated at a speed exceeding 25 knots, at an altitude greater than 400 feet above ground level, or, when visibility is less than 1 statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations will be conducted during the day under visual meteorological conditions. 3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization (" COA ) 4. All operations will use a pilot

- in

- command ("PIC") and a visual observer ("VO"), an d the UAS will remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS capability and the ability to communicate verbally with the VO at all times. 5. Focus

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- Video, LLC will ensure prior to operation that the PIC has demonstrated the ability to safely operate the UAS in a m anner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and st ru ctures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 C.F.R. § 61.51(b). 6. Focus

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- Video, LLC operating documents will be accessible during UAS operations and made available to the Administrator upon request. 7. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS 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 m aintenance has been performed and the U AS is found to be in a condition for safe flight. 8. Any UAS that has undergone 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 prior to conducting fu r ther operations under this exemption. 9. Focus

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- Video, LLC will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety bulletins, f or the aircraft and aircraft components. 10. Focus

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- Video, LLC will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.



### VI. THE FAA'S AUTHORITY TO GRANT THIS PETITIONThe FAA has authority to grant the exemption requested herein under the FMRA and the Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, and directs the Secretary of Transportation to determine which UAS, "as a result of their size, weight, speed, operational ca pability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security." 3 Section 333 further directs the Secretary to "establish requirements for the safe operation of such aircraft systems in the national airspace system. " 4 The Federal Aviation Act authorizes the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions of the Act where such exemptions are in the public interest. 5 Par t 11 of the Federal Aviation Regulations governs the FAA's exemption process and requirements. 6 The FAA has granted more than 1,100 exemptions to date pursuant to its Section 333 and exemption autho rity, enabling commercial UAS operations in a wide variety of industries.



### VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL RE GISTER Should the FAA determine that publication in the Federal Register is required, Focus

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- Video, LLC offers the following summ ar y pursuant to section 11.81 of the FAA's rules: 7 Petitioner: Focus

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- Video, LLC Sections of 14 C. FR. Affected: 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. 

### § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.15l(a)(l); 14 C.F.R. 

### § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91 .409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeks relief from the requirements of 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. § 9 1.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for newsgathering, content pro duction, and facilities inspection.



### VIII. CONCLUSION As demonstrated above, the UAS operations Focus

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- Video, LLC has proposed in this petition for exemption will garner significant public benefits while presenting minimal safety risks. Focus

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- Video, LLC petition satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous petitions the FAA has granted, meriting a summary grant of exemption. Focus

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- Video, LLC respectfully requests that the FAA grant this petition to enha nce Focus

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- Video, LLC ability to provide wedding and event photography and videography to its customers

. Sincerely, Bernard McRae Focus

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- Video, LLC Bernard@Focus

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- Video.com