October 7, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue SW

Washington, DC 20591

Applicant:

Ryan Detzel

Cinematographer

Brand Story Experts

1911 Manatee Ave E

Bradenton, Fl 34208­1562

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

Reform Act), and 14 C.F.R. Part 11, Ryan Detzel, a cinematographer, hereby

applies for an exemption on behalf of Brand Story Experts, a marketing agency,

from the Federal Aviation Regulations (FARs) listed below to allow operation of

our Unmanned Aircraft System (UAS) commercially in airspace regulated by the

Federal Aviation Administration (FAA) so long as such operations are conducted

with and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

The requested exemption would permit Ryan Detzel to pursue his commercial

interests in providing services to clients using a small advanced UAV in the

following areas: Marketing for commercial use. Ryan Detzel states that all UAS

flights will occur over private or controlled access property and will do so with the

property owner's consent and knowledge and that only people who have consented
or otherwise have agreed to be within the UAS’ radius during filming and

photography applications.

Ryan Detzel has demonstrated the ability to safely and effectively fly the UAS DJI

Inspire 1 which will be used for all commercial and private purposes. Ryan Detzel

complies with local ordinances and laws regarding the operation of UAS, and

adheres to all weather and environmental restrictions or limitations in reference to

the operations of UAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Ryan Detzel, am seeking the exemption because I am committed to complying

with all of the rules, guidelines, limitations, and future legislation set forth by the

FAA. I agree to operate the UAS in the manner that I have described, and for the

purposes that I have described. Without the exemption request granted, I would be

unable to safely and effectively run my business, and it is my intention to comply

with the FAA and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption,

and a summary of responsibilities I assume as operator; it also contains information

regarding the aircraft, public interest, public benefit and safety features, and similar

petitions requests granted.

Regulations from which I formally request exemption:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121
14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 ­ 91.417

Summary

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1

when weighing less than 12 pounds including payload. Proposed operations of any

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed­set motion picture and television filming

are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per

hour). The exemption holder may use either ground speed or calibrated airspeed to

determine compliance with the 87 knot speed restriction. In no case will the UA be

operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground

level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s FAA­issued airman medical

certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may

be used to satisfy the VLOS requirement as long as the PIC always maintains

VLOS capability. The VO and PIC must be able to communicate verbally at all

times; electronic messaging or texting is not permitted during flight operations.

The PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the VO can

perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in this grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and 4

limitations in this exemption and the procedures outlined in the operating

documents, the conditions and limitations herein take precedence and must be

followed. Otherwise, the operator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents.

It is the operator’s responsibility to track such revisions and present updated and

revised documents to the Administrator or any law enforcement official upon

request. The operator must also present updated and revised documents if it

petitions for extension or amendment to this grant of exemption. If the operator

determines that any update or revision would affect the basis upon which the FAA

granted this exemption, then the operator must petition for an amendment to its

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be

contacted if questions arise regarding updates or revisions to the operating

documents.

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,

must undergo a functional test flight prior to conducting further operations under

this exemption. Functional test flights may only be conducted by a PIC with a VO

and must remain at least 500 feet from other people. The functional test flight must

be conducted in such a manner so as to not pose an undue hazard to persons and

property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure

that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a preflight inspection and determine

the UAS is in a condition for safe flight. The pre­flight inspection must account for

all potential discrepancies, e.g., inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the

aircraft is prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and aircraft

components.

12. Each UAS operated under this exemption must comply with all manufacturer's

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold

a current FAA airman medical certificate or a valid U.S. driver’s license issued by

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the

Federal government. The PIC must also meet the flight review requirements

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her

pilot certificate. 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates

the ability to safely operate the UAS in a manner 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

structures. PIC qualification flight hours and currency must be logged in a manner

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the

operator’s PICs and VOs (training, proficiency, and experience­building) and

determining the PIC’s ability to safely operate the UAS in a manner consistent

with how the UAS will be operated under this exemption are permitted under the

terms of this exemption. However, training operations may only be conducted

during dedicated training sessions. During training, proficiency, and

experience­building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate

distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for

airports not denoted with an ARP, the center of the airport symbol as denoted on

the current FAA­published aeronautical chart, unless a letter of agreement with that
airport’s management is obtained or otherwise permitted by a COA issued to the

exemption holder. The letter of agreement with the airport management must be

made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return

to a pre­determined location within the private or controlled­access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough available power for the UA to conduct

the intended operation and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

All operations shall be conducted in accordance with an ATO­issued COA. The

exemption holder may apply for a new or amended COA if it intends to conduct

operations that cannot be conducted under the terms of the attached COA. 6

22. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have

identification (N−Number) markings in accordance with 14 CFR part 45, Subpart

C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the aircraft

is operating. These documents must be made available to the Administrator or any

law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or

structures are present that sufficiently protect nonparticipating persons from the
UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately in a manner ensuring the safety of

nonparticipating persons; and b. The owner/controller of any vessels, vehicles or

structures has granted permission for operating closer to those objects and the PIC

has made a safety assessment of the risk of operating closer to those objects and

determined that it does not present an undue hazard. The PIC, VO, operator

trainees or essential persons are not considered nonparticipating persons under this

exemption.

27. All operations shall be conducted over private or controlled­access property

with permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA must

be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours.

Accidents must be reported to the National Transportation Safety Board (NTSB)

per instructions contained on the NTSB Web site: www.ntsb.gov.

Similar Exemption

As found in Exemption No.11138 (Trudeau) the FAA recently approved similar

use of a Phantom 2 UAS. We will operate a UAS, The DJI Inspire 1, which is

comprised of an unmanned aircraft, an attached camera, and a “return­to­home”

feature.

The Inspire 1 is a quad­copter with a gross weight of about 6 1/2. It is driven by

four electric motors and has a max airspeed of 22 m/s only operating at 42.8kt of

allowed 87kt. It will be flown to augment marketing for commercial use and other

business operations.
Public Interest

Aerial photography and videography for commercial use are used to enhance

marketing strategies and increase business success. This industry is not new. With

this exemption I would be able to provide those specific marketing services.

Furthermore, the small UAS would pose no threat to the public given its small size

compared to a larger aircraft.

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an

aerial video gathering platform due to the smaller devices cheaper equipment and

personnel cost, reduced noise and as such, a much smaller environmental impact

which promotes public safety.

Ryan Detzel is petitioning for an exemption to operate a DJI Inspire 1 with a

built­in stabilized HD camera and GPS safety features which limit its ability to

limit the height it flies above ground level (AGL), to limit the radius of the distance

it flies from the operator and to exclude it from operations within designated Class

B, C and D airspace including a no­fly zone feature.

The DJI Inspire 1 also has a failsafe function that is triggered in the event

communication is lost between the sUAS and the main controller transmitter. At

that time, the sUAS will return to its point of takeoff and land safety. If the

connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set

below:

∙ The petitioner will only operate its sUAS in line­of­sight of a pilot and/or

observer and will operate at sites that are “sufficient distance” from populated

areas within the sterile area described in the FOPM. Such operations will ensure

that the sUAS will "not create a hazard to users of the national airspace system or

the public."
∙ When flying the sUAS within three (3) miles of an airport, airport operators will

be notified and the operator will give the right­of­way to avoid flying in the

proximity of full­scale aircraft. Maximum flight time for each operation will be 25

minutes.

∙ Flights will be terminated when battery levels reach 25%, allowing sufficient

reserve flight time to safely land the sUAS.

∙ The sUAS will be programmed so it will not be operated at an altitude that

exceeds 400 feet AGL, and not more than 200 feet above an elevated platform

from which videography is planned.

∙ Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS

observer, and the camera operator.

∙ The sUAS PIC will be an FAA licensed airman holding a minimum of a Private

Pilot certificate and a current FAA medical certificate.

∙ The sUAS operated by the petitioner weighs less than 25 pounds, including all

payload (i.e. camera, lens, and stabilized gimbal).

∙ The sUAS will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

∙ Given the small size of the sUAS and the restricted sterile environment within

which it will operate, operations adhere to the Reform Act's safety requirements.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012­

size, weight, speed, operating capabilities, proximity to airports and populated area

operations with VLOS and national security­ provide justification for the granting

of the requested exemptions allowing commercial operation of applicants sUAS in

aerial photography and cinematography.

Sincerely,

Ryan Detzel

Cinematographer

Brand Story Experts