John Flower Productions 607 W Main St. Ste. 201 Louisville, KY 40202 502-561-8000 john@johnflowerproductions.com

June 4, 2015

U.S. DepartmentofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New JerseyAvenue, SE

Re: Request for exemption under Section 333 from CFR Part 21, Subpart H; 14 CFR 61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 CFR Part 11,John Flower Productions hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial

use ofits Small Unmanned Aircraft Systems (SUASs), so long as such operations are conducted within and under the conditions outlined herein or as maybe established bythe FAA as required by Section 333.

An exemption is being requested because (1) existing regulations will burden John Flower Productions, (2) John Flower Productions can provide a level ofsafetythatis equal to or greaterthan those provided by existing rules, and (3) the request is in the public interest. The FAA's authorityto issue exemptions from operatingrules, and the Secretary's authoritygranted by Section 333 ofP.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunityto authorize certain SUAS operations in the National Airspace System (NAS) priorto implementation of the SAUS rule. This incremental step will allow John Flower Productions to safely and legally enter into the NAS.

As described in detail below, the requested exemption would permitJohn Flower Productions to operate SUASs under controlled conditions in airspace thatis (1) limited, (2) predetermined, (3) controlled as to access, and (4) would provide safety enhancements to the already safe operations ofthose aircraft ofsimilar size, weight, speed, and operating capabilitythathave been granted entryin the NAS via the rules in Academy ofModel Aeronautics (AMA) National Aircraft Safety Code. Approval ofthis exemption would thereby greatly enhance safety and fulfill the Secretary ofTransportation's (the Secretary) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system" per Section 333 (c) ofthe Reform Act.John Flower Productions is requesting exemption from the following regulations:

14 CFR Part 21, SubpartH 14 CFR 61.23 (a) 14 CFR 61.113 (a) and (b) 14 CFR 91.109 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(1) 14 CFR 91.409 (a)(2) 14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333 (a) through (c) ofthe Reform Act. This law directs to the Secretaryto considerwhether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretaryis required to determine which types of UASs do not create a hazard to users ofthe NAS, to the public, or pose a threat to national security.

Section 333 ofthe Reform Act grants the Secretary authority to determine (1) ifan unmanned aircraft system, as a result ofits size, weight, speed, operating capability, proximityto airports and populated areas, and operation within visual line ofsight (VLOS) does not create a hazard to users ofthe NAS orthe public or pose a threatto national security, and (2) whether a certificate ofwaiver, certificate of authorization, or airworthiness certification under 49 USC 44704 is required for the operation ofcivil (non-governmental) UASs. Therefore, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system". (John Flower Productions has interpreted this provision to place the duty on the Secretaryto not only process applications for exemptions under Section 3 3 3 ofthe Reform Act, butfor the Secretaryto craft conditions for safe operations ofSUAS. ifit should be determined thatthe conditions setforth herein do
not fulfill the statutoryrequirements for approval.

Corporate Overview

John Flower Productions' SUASs are quadcopters, weighing 6.5 lbs. orfewer (including payload.) The SUASs have the capabilityto hover and move in the vertical and horizontal planes simultaneously. Theywill operate only in visual line ofsight (VLOS) and will operate only in controlled and limited airspace. They are capable of operating at speeds ofup to 43 knots, butwill routinelybe operated at much lower speeds. Theywill routinely be operated below 200 feet above ground level (AGL,) and never above 400 feet AGL.John Flower Productions' exemption requestwould permitits commercial operation ofSUASs for aerial photography and videography in tightly controlled and limited airspace. Aerial photography and videography services will be offered to private events, commercial and personal realtors, home builders, golfcourses, home contractors, advertising agencies, privately and publicly held companies, andjor home inspectors for use in, butnot limited to, real estate marketing, safer inspections ofhomes, and general advertising and marketing purposes. Operations will always be conducted in areas that are free and clear ofall people, exceptthe pilotin command (PIC) and the PIC's assistant(s). Such operations will ensure that SUAS will "not create a hazard to users ofthe national airspace system orthe public." (taken from Reform Act Section 333 (b))

Aircraft

John Flower Productions operates Inspire 1 (http://www.dji.com/product!inspire1) SUASs manufactured by DJI, a well-known leader in quadcopter technology. DJI strives to bring newperspectives to aerial work and help companies accomplish feats safer, faster, and with greater efficiency. Theyhave an unparalleled commitmentto R&D, a culture ofconstant innovation, and a focus on transforming complex technology into easy-to-use devices.

The standard Inspire 1 quadcopter package includes the Inspire 1 itself, camera, gimbel, propulsion system, flight control system, 5.8 GHz remote controller, and 2.4 GHz communication system. The remote uses a 5.8 GHz frequency to prevent interference with the video/telemetrychannel. This second channel allows for a constant connection with the Inspire 1 to monitor it via a smartphonejtabletthatis attached to the remote controller.

The Inspire 1 is about 17.2 inches x 17.7 inches x 11.9 inches in size. It has a maximum ascent speed of 16.4 feet per second, a maximum descent speed of 13.1 feet per second, and a maximum flight speed of43 knots. While operatingwithin VLOS, the remote control has a range ofapproximately 2,600 feet. The total weight (including payload) is 6.4lbs. (http://store.dji.com/product/inspire1?position+1#spec).

The Inspire 1 is equipped with a flight control system thatprovides incredible ease ofuse and stability. Pilots can control the Inspire 1's movements in many directions -includingpitch (forward and backward), roll (left and right), elevator (up and down), and yaw (turn left and right). The flight control system can also provide intelligent orientation control, failsafe, batterylevel monitoring (and warnings), and showthe aircraft's currentheading, direction, and approximate distance from home

on the on-screen radar. The built-in GPS system aids in stabilizing the aircraft and automatically and safely returns is back to its home point in any case where communication betweenthe remote control and quadcopter are lost.The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter that measure both attitude (ATTl) and altitude. The IMU incorporates both

a 6-axis gyroscope and an accelerometer to monitor minuscule changes in tilt and movement. This allows the aircraftto compensate and adjust immediately, holding its position at all times.

The Inspire 1's compass reads geomagnetic information and assists the GPS to accurately calculate the position and height ofthe aircraft. The Inspire 1 also has a built-in Visual Positioning System (VPS) thatallows takeoffand landing atthe press ofa button and keeps the Inspire 1 steadywhen GPS satellites cannotbe required. The system combines visual data and sonarwaves in a single unit, detecting both variance in patterns on the ground and current altitude. Information from the VPS is processed bya dedicated CPU chip thattaken in feedback and outputs data in real time, and is intelligent enough to distinguish between objects and ground patterns. The data is given to the Inspire 1's flight controller, which in turns continues with the entire aircraft.

The Inspire 1 has LED flight indicators beneath each ofits four rotor arms. The LEDs

on the arms as well as one on the batteryilluminate to indicate the status ofthe flight control system and alertthe PIC ofany possible issues. Such highly advanced capabilities will ensure thatthe SUASs can be safely operated and "not create a hazard to users ofthe national space system or the public." (taken from the Reform Act Section 333 (b))

EquivalentLevel ofSafety

In an efforttojoin the FAA in its mission to provide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS orto persons and property on the ground, John Flower Productions agrees to be bound bythe following limitations and conditions when conducting commercial operations under

an FAA issued exemption:

A For the purposes ofensuring SUASs will be operated within the standards that the FAA has allowed in the AMA National Model Aircraft Safety Code: 1. SUASs will notbe flown: i. In a careless orreckless manner ii. At a location where SUAS activities are prohibited 2. SUAS pilots will: i. Yield the right ofwayto all human-carrying aircraft ii. See and avoid all aircraft and a spotter mustbe used when appropriate iii. Not fly higher than 400 feet AGL orwithin three (3) miles ofan airportwithout notifying the airport operatoriv. Not interfere with operations and traffic patterns at any airport, heliport, or seaplanebase except where there is a mixed use agreement

v. Not exceed a takeoffweight of55 pounds (including payload) vi. Ensure the aircraft is identified by affixing the owner's contact information to the outside ofthe SUAS vii. Not operate SUAS while under the influence ofalcohol ofwhile using any drug that could affect the PIC's ability to safely control the model viii. Not operate SUASs carrying pyrotechnic devices that explode

or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property 3. SUASs will notbe flown unless: i. The aircraft, control 

### system, and pilot skills have successfully demonstrated all maneuvers intended or anticipated priorto the specific event ii. An inexperienced pilot is assisted by an experienced pilot 4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment oflife and property ofothers 5. Asuccessful radio equipmentground-range check in accordance with manufacturer's recommendations will be completed before the first flight ofa new or repaired model aircraft 6. SUASs mustuse the radio-control frequencies currently allowed by the Federal Communications Commission (FCC) 7. SUASs will notknowingly operate within three (3) miles ofany existing pre-existing flying site without a frequency-management agreement 8. Excluding takeoffand landing, no SUASs may be flown closer than 25 feet to any individual, exceptfor PIC and the PIC's assistant(s) located atthe takeoffsite 9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, exceptto divert it from striking an individual 10.The PIC ofthe SUAS shall: i. Maintain control duringthe entire flight, maintainingvisual contactwithout enhancementotherthan by corrective lenses prescribed for the pilot ii. Fly using the assistance ofa camera or First-Person (FPV) only in accordance with the procedures outlined in AMA Document #550 iii. Fly using the assistance ofautopilot or stabilization system only in accordance with the procedures outlined inAMA Document #560 11. The flying area mustbe clear ofall utilitywire or poles and an SUAV will notbe flown closer than 50 feet to any above-ground electric utility lines12. The flying area mustbe clear before the engine is started, except for PIC and the PIC assistant(s) B. In addition to the above rules outlined bytheAMA National Model Aircraft Safety Code and in an effort to enhance the safety offered bythe already safe operations mentioned above, John Flower Productions also agrees to be bound bythe following limitations and conditions: 1. Flights will be operated within VLOS ofthe PIC 2. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that

occur priorto the 20 minute limit 3. The SUAS will only operate in tightly controlled and limited airspace 4. Abriefingwill be conducted in regard to the planned SUAS operations priorto each flight. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be presentfor this briefing 5. The PIC and PIC's assistant(s) will at all times be able to communicate by voice 6. Ifthe SUAS loses communications orloses its GS signal, the SUAS will have the capabilityto return to a pre-determined location within the securityperimeter and safely land 7. The SUAS will have the capabilityto abort a flight in case ofunpredicted obstacles or emergencies 8. All flights will be conducted with the written andjor oral permission of the owner/overseer ofthe property on which the flight is conducted 9. The PIC and the PIC's assistant(s) will have been trained in operation of SUAS and received up-to-date information on the particular SUAS to be operated 10. Flights will always be conducted in areas that are clear ofall people, except for the PIC and the PIC's assistant(s) 11. Flights will notbe conducted outdoors in visual meteorological conditions (VMC) and never during severeweather conditions 12. Flights will not occur in weather conditions thatpreventthe PIC from operatingwithin visual line ofsight at all times or in weather conditions that dramatically affect the SUAS's light (e.g. high winds) 13. Ifan operation occurs in an area where people could inadvertently enter the area, an operational borderwill be established with traffic cones. Ifit is not feasible to use traffic cones due to interference with the photographyjvideography, the PIC's assistant(s) will be responsible for keeping a safe perimeter around the operation. The operationwill cease immediately and be rescheduled ifitis impossible to establish a safe perimeter around the operation 14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as prescribed in the "Preventative Maintenance" section below 15. The SUAS will notbe routinely operated in the proximity ofany airports. In any cases where SUAS mustbe operatedwithin three (3) miles ofanairport, the airport operatorwill be notified before the operation

commences

The operation ofSUASs weighing less than 7lbs., conducted in the strict conditions

as outlined above, will provide an equivalentlevel ofsafety supportingthe grant of exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled environment.As a result, they offer a much saferwayto capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancementto the already safe operations thathave been granted bythe FAA for the establishment oftheAMA National Model Aircraft Safety Code.
PreflightAction Plan

The PIC will follow a comprehensive pre-flight checklistto ensurethatthe SUAS is in

a condition for safe flight. This plan will be improved as needed in orderto ensure all known safety precautions an/or safety precautions suggested by the manufacturer are being accounted for.

A Pre-flight Inspection 1. Check thatthe remote control, Inspire 1 battery, range extender, and smartphonejtabletare all fully charged. 2. Verify thatthe Inspire 1 batteryis not swollen or damaged in any way. Clean the contact needles and pads ifnecessary. 3. Turn the motor shafts with your fingers and verify they are smooth without excessive play orbinding. 4. Verify thatthe propellers are mounted correctly. Each propeller should spin all the way down onto the motor shaft and safety clips installed after the propeller. 5. Run finger along the edge ofthe propellerblade to check for any rough edges. 6. Flex both sides ofthe propellers' blades to check for hairline cracks wherethe blades connect in the center ofthe propeller. 7. Verify thatthe landing gear is secure (not cracked/broken/loose.) 8. Verify thatthe compass and compass cable are firmly attached to the landing gear. 9. Verify thatthe Micro-SD card has been inserted and formatted. 10. Verify thatthe damping absorbers are notbroken and/or worn. 11. Verify thatthe anti-drop pins are in place and locked. 12. Remove the gimbal guard and cameralens cap. 13. Verify thatthe camera is secure and clean. Inspectthe camera ribbon cables for tears and/or signs ofwear. 14.Verify thatthe smartphonejtablet's GPS is enabled.15. Set the smartphonejtabletto do-not-disturb mode to prevent distractions while flying. 16. Set the smartphonejtabletto forget anyWi-Fi networks in range in orderto preventthe Wi-Fi connections from changing midflight. 17. Verify thatthe smartphonejtablet's audio is on to ensurethe low batterywarning and other alarms can be heard. B. Power Up 1. Verify that S1 and S2 are in the center position on the remote control. 2. Power on the equipment. i. SUAS battery (blinking green indicates GPS lock and ready
to fly.) ii. Remote control (solid green and chime indicate lock on SUAS and ready to fly.) 3. Check the DJI Pilot app to ensure lock on 6+ sattelites and home point is marked (for use by the failsafe feature.) 4. Calibrate the compass. 5. Place the Inspire 1 on open, flat ground with the battery indicators facing toward the PIC atleast 10 feet away. C. DJI PilotApp 1. Connect the smartphonejtabletto the remote via USB 2. Launch the app. 3. Verify the number ofsatellites is 6+. 4. Verify signal strength. 5. Verify thatthe smartphonejtabletbatteryhas a full charge. 6. Verify thatboth the PIC's and the Inspire 1's location is the same before takeoffto ensure the home pointhas been accurately marked. 7. Verify the location ofthe Inspire 1 in the "flight radar." Ifitis notin the correctposition/direction and/or shows a distance of"NjA," it did not markthe home point. 8. Use the "find my Inspire" feature to ensure the blue (home point location) and the red (Inspire 1location) dots are in the same location on the screen. D. Ready to Fly 1. Verify thatthe remote antenna is perpendicularto the ground (pointing skyward.) 2. Verify thatthe front, flat face ofthe range extender is pointed toward the Inspire 1. 3. Verify thatthe rear LEDs are slowlyblinking green and still connected to 6+ satellites. 4. Startthe Inspire 1's motors using the remote control. 5. Verify the motors are functioning normally, and are not making any unusual noises, and are all spinning at the same speed.6. Verify thatthe area is clear ofobstructions, people, powerlines,
etc. 7. Take offand hover at about 6-8 feet above the takeoffpointto verify thatthe Inspire1 has a solid GPS lock. Ifany abnormalities

are noticed (drifting, flying in circles, etc) land immediately and repeatthe "Pre-flight Inspection" and "Power Up" sequences. 8. Verify the Inspire 1 holds a steadyposition while yawing 360 degrees. 9. Verify the Inspire 1 responds appropriatelyto all controls- yaw left/right, pitch forward/backward, and throttle up/down.

Preventative Maintenance

A comprehensive preventative maintenance plan will be followed in orderto ensure the SUAS's software is up-to-date, the batteries are in good health, and the aircraft itselfis always ready for safe flight.

Pilot In Command (PIC) Qualifications

The PIC does nothold an airman certificate or medical certification. Since the SUAS is similar in size, weight, speed, and operating capability as those currently allowed
to be flown for hobby /recreation, holding the PIC to those same set ofstandards will allowfor an equivalent level ofsafety.

The PIC has years ofelectronics and computer systems experience. Since the SUAS is controlled by a highly advanced computer system and runs on softwarethat must be configured, updated, and maintained, computer proficiency is a mustto ensure the SUAS is readyto be safely operated in the NAS.

It cannotbe assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL orlower, within strictly controlled pre-approved and determined airspace. Since there are no standards for either private or commercial SUAS pilot certificated, knowledge ofairspace regulations and dexterity in the control and operations ofthe SUAS acquired from actual operation ofthe aircraftwill be the most important factors in establishing level ofsafety. With that in mind, John Flower Productions proposes that its PIC be required to do the following priorto the first commercial operation:

1. Perform 20 flights or log 20 hours offlight time (the greater ofthe two) with the Inspire 1 2. Successfully learn and demonstrate all flight maneuvers in the Inspire 1 User Manual (http://download.djiinnovations.com/downloads!inspire 1/en!Inspire 1 User Manual v1.0

en.pdf) 3. Study and be familiar with all sections ofthe Inspire 1 User Manual

Public InterestGranting this exemption would benefitthe public as a whole. SUASs offer a strong equivalent level ofsafety, a reduction in environmental impacts, and are free from the harmful emissions associated with the manned aircraftthat are currently used for commercial aerial photography and videography. Due to the size ofthe SUAS and the tightly controlled and limited airspace in which the SUAS would operate, approval ofthis application presents no risk to the public.
Privacy

Since the areas being photographed orfilmed will be only upon receipt ofwritten andfor oral consentby the property owner or overseer and clear ofall people, except for the PIC and the PIC's assistant(s), approval ofthis application presents no riskto public privacy.

National Security

Due to the size ofthe SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval ofthis application presents no risk to national security.
Requested Exemptions

John Flower Productions requests exemption from the following regulations since it is notpossible to fully comply with them, and since attemptingto follow them for the purposes ofoperating SUAS would be a burden:

Airworthiness Certificate 14 CFR Part 21, Subpart H

Subpart Hestablishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203(a)(1). Given the size and limited operating area associated with the aircraftto be utilized byJohn Flower Productions, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 USC 44701(f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe weight, size, speed, operational capability, and proximityto airports and populated areas ofthe particular SUAS. In all cases, an analysis ofthese criteria demonstrated thatthe SUAS operated without an airworthiness certificate, in the restricted environmentand under the conditions proposed, will be atleast safe, or safer, than a conventional aircraft operatingwith

an airworthiness certificate withoutthe restrictions and conditions proposed.

Medical Certificates 14 CFR 61.23(a)

This regulation requires pilots ofmanned aircraftto hold a medical certificate. Since risks associated with the operation ofthe proposed SUAS as sodiminished from the level ofrisk associated with any manned aircraft; the SUAS is of

a size, weight, speed, and operational capabilities which make itmuch safer than any manned aircraft; since operations will occur in tightly controlled and limited airspace; and considering that all operations will be on approved propertythatis clear ofpeople, obtaining and maintaining a medical certificate would notimprove the safety ofthe operation. In the very rare case ofmishap, the USAS being flown will pose significantly less ofa threatthen manned helicopters and fixed wing aircraft because the SUAS are a fraction ofthe size and weight and will be flown at a fraction ofthe speed, carry no flammable fuel, and carry no crew or passengers.



### Private pilotprivileges and limitations: Pilot In Command 14 CFR 61.113(a) and (b)

These regulations limit private pilots to non-commercial operations. Because the SUAS will not carry a pilot or passengers; dues to the SUAS's size, weight, speed, and operational capabilities; and since operations will occur in tightly controlled and limited airspace, the proposed operations can achieve the equivalentlevel of safety ofcurrent operations thatrequire a commercial pilot's license. Furthermore, since there are no standards for either private or commercial SUAS pilot certificates, knowledge ofairspace regulations and dexterity in the control and operation ofthe SUAS acquired form actual operation ofthe aircraft will be the mostimportant factors in establishing an equivalentlevel ofsafety. It cannotbe assumed that a commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill or abilityto safely operate an unmanned aerial vehicle, operating at400 feet AGL orlower, within strictly controlled and pre-approved airspace.



### Flight Instruction 14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls.

SUAS and remotely piloted aircraft, by their design do nothave fully functional dual controls. Flight control id accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafetywill be provided by the fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft.



### Altimeter Settings 14 CFR 91.121

This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeter thatis set"

...to the elevation ofthedeparture airport or an appropriate altimeter setting available before departure." As the SUAS may nothave a barometric altimeter, butinstead a GPS altitude readout,

an exemption maybe needed. An equivalentlevel ofsafety will be achieved bythe operator confirmingthe altitude ofthe launch site shown in the GPS altitude indicatorbefore flight.

Fuel Requirements for Flight in VFR Conditions 14 CFR 91.151(a)

This regulation prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after thatfor atleast 30 minutes;

or (2) At night, to fly after thatfor atleast45 minutes."

The batterypowering the SUAS provides approximately 20 minutes of powered flight. That makes itimpossible to meetthe 30-minute reserve requirement. Given the limitations on the SUAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

An equivalent level ofsafety can be achieved by limiting flight to 20 minutes

or 25% ofbattery (whichever occurs first). This restrictionwould be more than adequate to return the SUAS to its planned landing zone from anywhere in its limited operating area.

Maintenance Inspections 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417(a) and (b)

These regulations require that an aircraft operator or owner "shall have the aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part43.

Given thatthese sections and Part43 apply only to aircraftwith an airworthiness certificate, these sections will not apply. Maintenance will be accomplished bythe operator pursuantto the aforementioned Inspire 1 user manual. An equivalentlevel ofsafety will be achieved because these small SUAS are very limited in size, will carry a small payload, and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise, the SUAS will be operating from no higher than 400 feet AGL and can land immediately. As outlined in the aforementioned Pre-flight action plan, the operatorwill ensure thatthe SUAS is in working order priorto initiating flight and perform maintenance as required. Moreover, the operator is the person mostfamiliar with the aircraft and best suitedto maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

In accordance with 14 CFR Part 11, the following summaryis provided for publication in the Federal Register:

The applicant seeks and exemption from the following rules: CFR Part 21, Subpart H; 14 CFR 61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) and (b) to commercially operate small unmanned aircraft systems (SSlbs. orless) in orderto safely and legally capture aerial photography and videography for use by commercial and personal realtors, home builders, golfcourses, home contractors, advertising agencies, privately and publicly held companies, andjorhome inspectors.

The operation ofSUAS conducted in the strict conditions outlined above will provide an equivalent and/or greaterlevel ofsafety supportingthe grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a result, are far safer than existing operations conducted with helicopters in close proximityto the ground, people, or other buildings in the vicinity.

Given the small size ofthe SUAS involved, the slow speed atwhich they mustbe operated in orderto capture photos and videos, and the restricted environment within which theywill operate, the Inspire 1 demonstrates thatit can be operated within an equivalentlevel ofsafetyin which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofSUAS to commence immediately. Also, due to the size ofthe SUAS and the restricted areas in which the relevant SUAS will operate, approval ofthis application presents no threatto national security. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, the strong equivalentlevel ofsafety surroundingthe proposed operations, the significantpublic benefit- including enhanced safety, reduction in environmental impacts, no emissions, ability to legally obtain aerial photography and videography services- the grant ofthe requested exemptions is in the public interest. Accordingly, John Flower Productions respectfully requests that the FAA grantthe requested exemption without delay.

Satisfaction ofthe criteria provided in Section 3 3 3 ofthe Reform Act- size, weight, speed, operating capability, proximityto airports and populated areas, operation within the visual line ofsight, public safety, and national security- providing more than adequatejustificationto grantJohn Flower Productions the requested exemption, allowing for commercial operations as described herewith.
Sincerely,

# ~ John Flower Owner, John Flower Productions