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I U.S
. Department ofTransportation Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE. Washington, DC 20590 February 10, 2016 Craig Huey Photography, LLC C/o Craig Huey 12079 Olmstead Drive Fayetteville, Georgia 30215 Email: Craig@CraigHueyPhotography.com

Subject: Exemption Request under Section 333, FAA Modernization and Reform Act, Part 11 of FARs 14 C.F.R. 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.103, 91.119(c), 91.121, 91.151(a), 91 .405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), 91.7(a), 91.9(b)(2)
Dear FAA Representative: Please accept this letter as official application for exemption of the Federal Aviation Association Modernization and Reform Act of 2012, Section 333, Federal Aviation Regulations ("FARs"), in accordance with 14 C.F.R
. Part 11 for allowance of commercial operation of Unmanned Aircraft Systems (UAS) platforms. This exemption comes at the request of Craig Huey Photography, LLC, petitioner and owner of UAS. 

### Proposed Operations Petitioner seeks relief from the listed regulations in order to operate a small UAS, commercially, in airspace regulated by the Federal Aviation Administration (FAA) for the purpose of aerial photography, videograph/, and other aerial operations at a lower altitude within the national and international airspace. Only authorized representatives of Craig Huey Photography, LLC, being 17 years of age or older with a valid United States driver's license, will operate UAS flights under the conditions outlined herein and as established by the FAA as requ ired by Section 333. Petitioner wishes exemption to operate UA Multifunctional Quad-rotor Systems by DJI for compensation or hire within the National and International Airspace System as needed by clients. Current specification sfor the OJ I UAS are as follows: 

### UAS Specifications
Aircraft 

# II Phantom 3 

# II Phantom 3 

# I Phantom 3 (4K) 

### II Inspire 1 (Professional) (Standard) Diagonal Size (Including 689mm 

# II 689mm 

# II 689mm 

# II 438x451x301 mm Propellers) Weight: (Including Battery 1280 g 

# II 1216 g 

# II 1280g 

### II 2935 g and Propellers)

Flight Time About 23 mins 

# II About 25 mins 

# II About 25 mins 

# II About 18 mins

1 Please note that videography services by petitioner consist oftestimonials, interviews, and b-roil (extra footage of images) obtained at corporate membership events
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# I 

# I I Aircraft 

# I Phantom 3 Phantom 3 

# I Phantom 3 (4K) 

# II Inspire 1 (Professional) (Standard) Max. Flight Speed 

# II 16m/s 

# II 16m/s 

# II 16m/s 

# II 22 m/s CE: 3500 m CE: 500m CE: 500m CE: 3500 m Max Transmission Distance FCC: 5000 m FCC : 1000m FCC: 1200m FCC: 5000 m (unobstructed) (unobstructed) (unobstructed) (unobstructed) Operating Temps 

# II ooc to 40°C 

# II ooc to 40°C 

# II ooc to 40°C 

# II Minus lOoCto 40°C 

### C.F.R.s 45.23(b): The UAS has no entrance to a cabin, cockpit or pilot station upon where the word " Experimental" can be placed
. The size of the drone prevents two-inch lettering given the size of the UAS. For these reasons the petitioner requests relief. In compliance with 14 C.F.R. 45
.29, the word "Experimental" will be placed on the fuselage based on issued Exemption Nos. 10700, 14226, and 10167
. 61 .23(a) and (c): Relief is requested because the Pilot-in-C ommand (PIC) needs to have EITHER a current medical certificate OR a valid United S tates issued driver's license and demonstrate the abil ity to safely operate the UAS
. PIC will be able to do evasive and em ergency maneuvers such as, but not lim ited to, maintaining appropriate distances from people and property
. FAA has previously allowed relief in Exemption Nos . 11772 and 12688. 61.101(e)(4) and (5): The UAS does not carry pilot and passengers given its size and speed. The UAS is remotely controlled and the area of operation will be coordinated with the permission of the property owner and hiring company's representative in advance. The FAA has issued the following exemptions to this regulation: Exemption Nos.11275, 11 269, 12033
. 61.113(a): Petitioner requests relief to utilize an experienced UAS operator with an optional UAS trained observer. Stated usage ofthe UAS will not pose a threat to National Airspace System, national security or the public, as it will not be flown above the maximum altitude of 500 feet from ground level, which is programmed into the UAS. The UAS will be operated within the visual line of sight of the operator and/or visual observer unaided by any device other than corrective lenses. 61.31S(a): Petitioner requests relief for any UAS PIC, acting on behalf of petitioner, who holds a sport pilot, recreational pilot or private pilot certificate, as well as, an airman medical certificate, to have permission to operate UAS flight operations for compensation or hire. (Exemption Nos. 11772 and 12594) 91.103: Petitioner request relief for separate preflight actions, which are required in using an UAS. The PIC will perform preflight actions as recommended by each correspond ing UAS manual, such as, but not limited to verifying weather conditions, battery status, and propellers
. These actions will provide safety
. (Exemption Nos. 11294, 11062 and 11191) 91.119(c): The petit ioner requests relief concerning UASflight over "congested" or "populated" areas as stated in Exemption No. 11138 to permit responsible operation in areas of outdoor corporate events when required. Based on the hover accuracy, the UAS will not be operated lower than four (4) feet of the tallest person or property in a populated area for safety based on the average ability of a person jumping from a standing position. The lack of flammable fuel on the UAS and the low-altitude compared to aircrafts, such as helicopters, diminish risks

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# I 

# I
Iassociated with operational compliance in this particular section
. Consent of operation for commercial usage will be obtained from local municipality and their designated agent. 

### 91.121: The UAS does not have an altimeter. It uses an electronic GPS with a barometric sensor for altitude; thereby, making the requirement inapplicable as stated in Exemption No. 11138. Altitude data is generated by the computing system on the UAS. 

### 91.151(a): Petitioner requests relief based on Exemption Nos. 10673, 10808, 11136 to operate a UAS in a controlled area with less than thirty {30) minutes of reserve fuel according to daytime Visual Flight Rules. The average flight time is 23 minutes. In the case of low battery level, the onboard flight controllers are designed to warn the operator to allow safe landing. A failsafe for loss of Global Positioning System or RC signal strength is also designed into the UAS to return to an established landing location. 

### 91.405{a), 91.407{a)(1), 91.409{a)(1) and (2), 91.417(a) and (b): Prior to usage of the UAS, a preflight checklist will be used as a guideline for visual inspection to insure safe operation. Records of the preflight checklist for each "for hire" job will be made available to the FAA, upon request. As stated in Exemption No. 11138, FAA found that inspection performed by the petitioner based on the manual operating document's requirements for maintenance, inspection, and logging is sufficient to ensure safety. 

### 91.7(a): Petitioner requests relief to operate a UAS based on the size, weight, speed, and limited area of flight as stated in Exemption Nos. 14225 and 14234. 

### 91.9(b)(2): Petitioner requests relief since there are no pilots or passengers on the UAS given its size
. The flight manual will be maintained at the ground control point where the operator of the UAS will have access to it. FAA has given prior approval to this in Exemption Nos
. 10167, 10602, and 10700
. 

### Safety Compensated tasks will be conducted only at the request and authorization of clients or their authorized agents in compliance with Privacy Laws and FAA Regulations. UAS operation will require completion of a pre- and post-flight checklist of flight readiness of UAS. Any and all accidents that result in injury or property damage will be reported to the FAA within ten (10) days
. All operations of the UAS will occur over private or controlled properties with consent of the hiring company's representative(s). Videography will be performed with consent of all persons in attendance
. Choice of usage of an UAS is to enhance safety and reduce environmental impact compared to usage of a manned aircraft. Petitioner promises to uphold the following proposed drone rules:



### • May only be operated from officialsunrise to officialsunset, (local time). • Must yield the right-of-way to otheraircraft, whethermannedor unmanned. • May beflown using "first-person view,"buteither the operatoror the visualobserver mustmaintain an unenhanced visual line ofsightofthe craft. • May beflown in minimum weather visibility of 3 milesfrom the operator. • May notbeflown in Class A (18,000feet & 

### above) airspace. • May beflown in Class B, C , 

### Dand Eairspace withATCpermission. • May be flown in Class Gairspace are allowed withoutATCpermission. • May notbeflown carelessly or recklessly
. • Require apreflight inspection before eachflight, including specific aircraft and control station systems checks, to ensure the drone is safefor operation.

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### • May notbe flown by aperson ifhe orshe knows orhas reason to know ofanyphysical or mentalcondition that would interfere with its safe operation. • No person mayact as an operatororvisual observer for more than one unmanned aircraft operation atone time. 

### Public Interest Safe UAS operations conducted within the FAA guidelines will support local and national businesses. Usage of UAS would allow Petitioner to expand services to include compliant and safe UAS services with the expectation of economic growth by providing imaging data for the purpose of a "for hire" basis while acting as an independent contractor. Operations of these services allow clients to gain enhanced perspectives of photographic and videographic images. Petitioner will provide safe and reliable aerial videography and photography services for marketing purposes of corporate events such as, conferences, expositions, annual meetings, symposiums, and tradeshows; as well as, documenting projects for businesses, such as, but not limited to, corporations, real estate, golf courses, marketing and advertising, architecture, and agriculture. Aerial images or video of outside events such as, sports, dinners, cocktails, and other corporate events could be provided in a safe manner compared to using a manned aircraft. 

### International Request Petitioner currently has 16 years of experience providing photography and videography services to national and international clients. Because current local and national clients conduct similar events internationally, petitioner further wishes permission, according to 14 CFR 11.83, to exercise the privileges of the requested exemptions outside the United States. Operation of UAS will not be conducted without prior location approval obtained by the client with respect to the international country and local regulations. UAS will only be operated internationally during "for hire" work and flight data will be logged and available to FAA, upon request. Petitioner understands approval by FAA for usage of UAS in the United States, does not take precedence over a possible disapproval within an international country. Best Regards,



# Gt2~~ **~** CraigA.Huey



# ~r Craig Huey Photography, LLC

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