Double	I	Media,	LLC

Attn:	David	Agler,	Owner 210	Charring	Cross	Dr	S Westerville,	OH	43081 614

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- 2508 dave@doubleimedia.com www.doubleimedia.com February 2 4, 2016 U.S.	Department	of	Transportation Docket Management	System 1200	New	Jersey	Avenue SE	Washington,	DC	20590 Subject:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11 .61 of	the Federal	Aviation	Regulations	from 14	C.F.R.	Parts 21,	(h),	91.203(a)& (b),	91.9,	45.23, 45.27(a),	45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1), (b)(2),		91.105,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405, 91.407,	91.409,	&	91.417

Pursuant	to	Section	333	of the	FAA	Modernization	and	Reform	Act	of	2012	and	14 C.F.R.	Part	11 .61 , Double	I	Media,	LLC, respectfully seeks an	exemption	from	the	following Code	of	Federal Regulations	(C.F.R.)	to	be	allowed	commercial	operation	of	lightweight Unmanned Aircraft	Systems (UAS)	for :

 aerial	imaging	and	videos	for	insp ection	and	sale	of	real	estate,  inspection	of	structures	for	engineering	and	architectural	purposes  closed	set	commercial	and	film	production  video	and	still	image	production	for	advertising	and	other business	needs  inspection	and	survey	of	wildlife,	plant,	and	other	resources	for	land	management  mappin g,	inspection,	and	survey	of	open	mining	and	landfill	operations  mapping,	inspection,	and	survey	of	utilities,	gas,	and	oil	facilities  mapping,	inspectio n,	and	survey	of	agriculture  mapping,	inspection,	and	survey	of	construction	sites  mapping,	inspection,	and	survey	of	disaster	areas

Double	I	Media,	LLC,	respectfully	seeks	an	exemption	from	the	following	Code	of	Federal Regulations	(C.F.R.): 14	C.F.R. Parts 21,	(h),	91.203(a)&(b),	91.9,	45.23,	45.27(a), 45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1),	(b)(2),91.105,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405,	91.407,

91.409,	&	91.417 This	exemption	request	seeks	permission	to	operate for	commercial	purposes the	Ph antom 3	Pro	and	Inspire	1	models	of	UAS	manufactured	by	DJI.	These	are	highly	reliable	industry

standard	platforms	and	have	been	approved	for	use	under numerous exemptions alr eady granted	according	to	the	criteria	detailed	in Section 333 of Public Law 112 −95. Double	I	Media,	LLC, and	any	pilots	and/or	other	personnel it employs in	the	operation	of an	UAS	in	the	NAS, will	abide	by	all	FAA	requirements from	which	relief	has	not	been granted	by	this	requested	exemption, to	ensure	this exemption	will	provide	a	level	of	safety at	least	equal	to	existing	rules	and	will	only operate	in	safe	environments that are	strictly controlled,	are away	from aerial navi gation	hazards, power	lines, elevated	lights,	airports and highly populated	areas. All	participating persons	employed	by Double	I	Media,	LLC , and any	other	operational and/or	participating personnel, will	conduct all preflight	inspections and preparations as	are	necessary	to	guarantee	the	safe	and	proper	operation	of	the	UAS s . 

## Requests	for	Relief 14	C.F.R.	Parts 21,	(h),	91.203(a) & (b),	91.9 Due	to	the	weight,	dimensions,	velocity,	and	limited	area	of	operation	associated	with	the UASs	referenced	in	th is	request,	relief	from	14	CFR	part	21,	Subpart	H,	91.203	(a)	and	(b), and	91.9	is	requested. The	UASs	to	be	used	weight	less	than	55	pounds,	are	powered	by	electric	motors,	carry	no flammable	liquids	or	fuel,	carry	no	passengers	or	cargo,	are	constructe d	largely	of	plastic and	other	flexible	materials,	and	will	be	operated	in	environments	under	observation	by one	or	more	persons	other	than	the	PIC	(Pilot	in	Control). Given	all	of	these	details,	the	UASs	are	able	to	operate	with	at	least	an	equivalent	l evel	of safety	as	other	aircraft.	Additionally,	the	UASs	will	not	receive	a	traditional	certificate	of airworthiness,	and	will	have	no	internal	space	to	display	or	carry	documents.	A	copy	of	the certificate	of	authorization	and	all	operator	manuals	will	be maintained	with	the	other required	records	held	by	the	PIC	in	the	area	of	operation	for	each	mission. 14	C.F.R.	Parts 45.23,	45.27(a),	45.29(3)(c)(d)(e)(f)(g)(h) Due	to	the	small	size	of	the	UASs,	relief	is	requested	from	14	C.F.R.	Parts	45.23 , 45.27(a) , and	4 5.29(3)(c)(d)(e)(f)(g)(h) .	There	is	very	little	space	upon	wh ich to	place	markings,	and given	the	small	size	of	the	UASs,	it	is	unlikely	that	any	markings	made	would	be	legible while	in	operation. All	UASs	will	be	marked	with	an	N	number	dis played	legibly	in	the largest	possible	size	characters so	that	they	may	be properly identified.	However,	due	tothe	very	small	size	of	the	UASs,	markings	as	described	in	14	C.F.R.	Parts	45.23 , 45.27(a) ,

and	4 5.29(3)(c)(d)(e)(f) (g)(h) are	not	practical. 14	C.F.R.	Parts	61.3,	61.133(a),	and	61.113	(a)	&	(b) Due	to	the	small	weight	and	size,	lack	of	combustible	fuel,	crew,	passengers,	and	cargo, relief	is	requested	from 14	C.F.R.	Parts	61.3,	61.133(a),	and	61.113	(a)	&	(b). A	commercial pilot	certification will	not	train	the	PIC	(Pilot	in	Control)	in	the	safe	and	competent operation	of	a	UAS.	Furthermore,	given	the	characteristics	of	the	UASs,	the	skills	obtained by	qualifying	for	a	commercial	pilot	certification	are	not	necessary	to	operate	the	UASs,	in	a manner	that	does	not	endanger	or	conflict	with	other	aircraft	operating	in	the	NAS,	and does	not	endanger	persons	or	property	on	the	ground. 14	C.F.R.	Part 91.103,	(b)(1),	(b)(2) Relief	is	requested	from	14	C.F.R.	91.103,(b)(1),(b)(2)	due	to	the	fact that	UASs	operations are	not	conducted	near,	and	are	prohibited	from	taking	place	at,	airports.	An	appropriate measure	of	safety	will	be	provided	by	completing	preflight	actions	as	described by	the manufacturer’s	manuals. 14	C.F.R.	Parts 91.105 The	UASs does	not	carry	a	crew,	so	there	are	no	crewmembers aboard,	and	no	stations	to be	manned.	The	actions	of	the	PIC	are	required	to	operate	the	UASs,	so	the	pilot	must maintain	contact	with	and	control	of	the	Remote	Controller	at	all	times	during	flight.	The PIC	will	not	change	during	operation	of	the	UASs,	and	both	the	PIC	and	Safety	Observer	will always	be	clearly	identified	prior	to	the	start	of	each	mission. 14	C.F.R.	Parts 91.109(a)	&	91.319(a)(1) The	UASs	does	not	have	a	crew,	and	for	this	reason	ther e	is	no	seatbelt	or	restraint necessary	to	the	safe	operation	of	the	UASs.	The	UASs	is	controlled	by	a	single	controller,	so dual	control	is	not	an	option	for	training.	All	training	missions	for	new	pilots	will	be conducted	at	low	altitudes	in	remote	locations	away	from	uninvolved	persons	and property. 14	C.F.R.	Part 91.119 Given	the	size,	weight,	flight	characteristics,	and	lack	of	combustible	fuel	or	payload,	relief from	the	500	foot	distance	requirement	is	requested.	The	UASs	operations	pose	little	ri sk to	persons	in	the	area	of	operation.	All	operations	will	be	conducted	with	the	consent	of	the property	owner,	and	all	persons	operating	or	that	have	property	in	the	operating	area	will be	made	aware	of	the	operations,	and	all	reasonable	measures	will	be taken	to	ensure	thatpersons	and	property	in	the	area	of	operation	are	at	the	least	possible	risk	of	contact	with

the	UASs.	Additionally,	the	missions	the	UASs	will	fly	do	not	require	achieving	altitudes	of more	than	400	feet	AGL. 14	C.F.R.	Part 91.121 The	UASs	utilize	a	barometric	pressure	sensor,	and	GPS	systems	to	calculate	the	altitude. These	are	self

- calibrated	by	the	flight	systems	of	the	UASs	and	require	no	manual	reset	or synchronization	with	secondary	ground

- based	systems	and/or	nearby	airports. Additionally,	the	UASs	will	only	be	operated	under	400	feet	AGL.	As	such,	relief	is	requested from	14	CFR	91.121. 14	C.F.R.	Part 91.151,(a)	91.151(b) The	UASs	use	electric	motors	powered	by	batteries,	and	as	such,	do	not	carry	fuel.	The maximum	length	of	operation	on	a	single	charge	is	not	more	than	20	minutes.	For	this reason,	relief	is	requested	from	14	CFR	91.151,	as	the	operational	characteristics	o f	the UASs	do	not	permit	flight	for	the	duration	required	by	the	regulation.	Given	the	very	small area	of	operation	and	the	size	of	the	UASs,	an	equivalent	level	of	safety	will	be	achieved	by ensuring	that	the	battery	is	at	full	charge	at	takeoff,	and	miss ions	are	terminated	when	the battery	charge	reaches	25%. 14	C.F.R.	Parts 91.405,	91.407,	91.409,	&	91.417 As	the	UASs	in	service	are	simple	machines	of	a	small	size	and	uncomplicated	nature,	relief is	requested	from	14	CFR	91.405,	91.407,	91.409,	and	91. 417.	The	PIC	will	perform	a preflight	inspection	prior	to	the	start	of	each	mission.	Any	required	simple	maintenance will	be	completed	and	documented	by	the	PIC.	Any	regular	maintenance	or	detailed inspection	mandated	or	recommended	by	the	manufacturer	wil l	be	performed	by	qualified personnel	at	the	place	of	purchase	of	the	UASs,	and	documented	by	the	PIC.

## Conclusion

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14 C.F.R.	Part	11 .61 ,	Double	I	Media,	LLC, respectfully	seeks	an	exemption	from	the	following Code	of	Federal	Regulations	(C.F.R.)	to	be	allowed	commercial	operation	of	lightweight Unmanned	Aircraft	Systems	(UAS)	for:

 aerial	imaging	and	videos	for	inspection	and	sale	of	real	estate,  inspection	of structures	for	engineering	and	architectural	purposes  closed	set	commercial	and	film	production  video	and	still	image	production	for	advertising	and	other	business	needs  inspection	and	survey	of	wildlife,	plant,	and	other	resources	for	land	management  map ping,	inspection,	and	survey	of	open	mining	and	landfill	operations  mapping,	inspection,	and	survey	of	utilities,	gas,	and	oil	facilities  mapping,	inspection,	and	survey	of	agriculture  mapping,	inspection,	and	survey	of	construction	sites Double	I	Media, LLC,	respectfully	seeks	an	exemption	from	the	following	Code	of	Federal Regulations	(C.F.R.): 14	C.F.R.	Parts 21,	(h),	91.203(a)&(b),	91.9,	45.23,	45.27(a), 45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1),	(b)(2), 91.105 ,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405,	91.407, 91.409,	&	91.417

Respectfully	submitted,

Double	I	Media,	LLC Attn:	David	Agler,	Owner 210	Charring	Cross	Dr	S Westerville,	OH	43081 614

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- 2508 dave@doubleimedia.com www.doubleimedia.com