Page 1 M a r c h 6 t h , 2016

U.S Department of Transportation
Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b); 91.203(a) and (b); 45.23(b); 91.9(b)(2).

To whomever it may concern, Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and reform Act, we, Lee Hiner & Trevor Hiner, co

owner/operators of an Unmanned Aircraft System (UAS), hereby apply, on beh alf of Aspect Aerial Media, for an exemption from the below listed Federal Aviation Regulations (”FARs”) to allow for the Commercial use of UASs, so long as these operations are performed within and under the specific terms outlined within this request or as established by the FAA as demanded by Section 333.

We would like to formally submit a request for an exemption from part 11, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)( 1), 91.409(a)(1) (a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the pu rpose of
contracted aerial v i d e o and photography for surv ey work and real estate sales purposes.

Applicant:

Trevor Hiner Creative Director/Principal
Lee Hiner Business Director/Principal Aspect Aerial Media
19904 31st Dr. SE Bothell, WA 98012

trevor14hiner@gmail.com (206)

- 962

- 1349 lee.hiner@frontier.com (206) 450

- 2729

Business and UAS Overview:

Business/Commercial operations for Aspect Aerial Media will include use of UASs, equipped with cameras and sensors to operate in specifically re quested areas to provide aerial photography and/orPage 2 video for public and/or private use including real estate, surveying, visual inspection services and other promotional sales and informational purposes. As described in full below, the requested exemption would permit our company the legal operation of a UAS under controlled conditions in the National Air Space (NAS) that would be planned and conducted safely and cautiously in line with current safe FAA rules & guidelines presently followed by private and commercial aircraft operators.

As found in exemption No. 11138 (Trudeau), the FAA has recently approved the similar use of a UAS, specifically the Phantom 3 UAS. Our company, Aspect Aerial Media, will operate the DJI Phantom 4 model; comprised of a UAS, attached 4k camera and a portab le ground control station. T h i s n e w m o d e l offers upgrades in safety and performance above and beyond previous models. Among these safety upgrades are an Automated Obstacle Avoidance sensors which detect objects from between 2 and 49 feet away allowing for automated avoidance.

The Phantom 4 is quad

- copter with a gross total weight of 3.05 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UAS has a maximum top airspeed of 20 m/s in its high p erformance sport mode with speeds slightly lesser in other modes. It will be operated primarily over various metropolitan, suburban and rural areas in and around the greater Seattle area and Washington State, to further augment real estate listings with still photos and video edits to enhance buyer’s and seller’s ability to market, display and communicate structure and property boundary details. In survey work for federal, state, county and private interests which could include timber, wildlife and others. W e will also offer contract film and video w ork and stock photography and vide o purposes in remote and or backcountry settings.

UAS Fl ight & Operational Parameters:

We have developed and will abide by the following operating parameters considering these requested exemptions to ensure a level of safety specific to UAS operation equal to the existing set of rules for
conventional aircraft :

• Operate the UAS below 400 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual observation.

• Operate strictly during daylight hours

• Obtain permission from the owner/controller of any vessels, vehicles and structures when

opera tions may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a preliminary safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard.

• Never fly near or around conventional aircraft or helicopters or emergency operations or response efforts.

• Operate the UAS for only 5

- 10 minutes per flight. (A maximum of 35% of a single Ba ttery Life)

.

• Land the UAS prior to the manufacturer’s recommended minimum level of battery power.

• Operate UAS du ring daylight hours only within a visual line of sight (VLOS).Page 3 • Use the UAS’ global positioning sys tem (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost.

• Conduct all operations under the flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) and will actively analyze flight data and other sources of information to constantly upda te and enhance safety protocols.

• Contact respective airports if operations will be within 5 miles to advise them of the estimated time of flight, flight duration, elevation of flight and other valuable information.

• Always obtain all necessary and man datory permissions prior to operation.

• Only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through obt aining information regarding congested areas from the local Flight Standards District Office (FSDO)

.

• Conduct extensive preflight inspections and protocols, during which safety carries primary importance (reference PHANTOM Flying Flowchart and User Manua l)

.

• Establish procedures and criteria to abort flights in the event of safety breaches or potential danger.

Training and Competence:

As UAS operational training, we have and continue to perform many practice flights in remote areas as hobbyist s simulating flights for future commercial use to gain familiarization with the characteristics of our UAS’ performance under different temperature and weather conditions.

Any Pilot in Control (PIC) operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating t he same make and model of UAS to be used for operations. In addition to the hour require ments, the PIC will accomplish 12 take

- offs and landings in the preceding 90 days (for current operational competence purposes) prior to any flight.

Specific Exemptions Requested:

Given the size, weight, speed, and limited operating area associated with the UA, we request an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). This exemption has further been granted in the cases of exemption No’s. 11650 and
11734.

We reque st an exemption from § 45.23 Marking of the aircraft

- because the UA S will not have a cabin, cockpit or pilot station on which to mark such certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft with dimensions s maller than the minimal lettering requirement. In lieu of this, we can/ will mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that anyone can/will see the markings.Page 4 We request an exe mption from § 91.7(a ) Civil Aircraft Airworthiness

- which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our UAS operation. Even without a certif icate, the pilot will uphold and ensure the spirit of this guideline for airworthiness of the UAS through the use and strict adherence to the Manufacturer ’ s Operation manual, preventative maintenance and preflight checks.

We request an exemption from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they appear only to apply to aircraft with an airworthiness certificate. Regardless, as a safety precaution we will perform a mandatory preflight inspection of the UAS before each flight.

We request an exemption from § 91.9(b)(2) which requires an aircraft f light manual in the aircraft. There are no pilots or passengers on board the aircraft and given its size. We believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. This will ensure
the sam e level of safety, equivalent to and in the same intended purpose of having a manual onboard in a
manned aircraft.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be o perated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equi valent to or below those in relation to minimum safe altitudes.” Due to the small size, weight, maneuverability, and speed of the UAS, an equivalent or even higher level of safety will be achieved and maintained.

We request an exemption from § 91.121 Alti meter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor to determine height and maintain a safe altitude at any given time. PIC will have real time access to Altitude information via the heads up display informat ion during navigation on the control panel.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued. According to our operating parameters, the UAV will
be land ed before and or at the first alert. Further, our flights will last only 5

- 10 minutes each, and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless (considering wind a nd forecast weather conditions) there is enough power to fly to the first point of predetermined landing and, assuming normal cruising speed, land the UAS with at least 30% battery power remaining.

Public Interest

Ae rial photography and video for real estate , various family or public events and business survey and inspection purposes are proven methods to enhance marketing efforts , reduce cost and environmental impact which can further increase business success matching buyers and seller s, family or other event

a rchiving and preservation and increased safety and reduced costs in preventative maintenance for companies performing these activities by other means historically.

The industry is not new. However, until recently it was conducted through the use of costly conv entional aircraft, a prohibitive business activity for small companies due to the extreme cost involved. By granting this exemption, we would be able to provide affordable services to private individuals, local & remote companies and Feder al, State and other such public agencies at low er cost, lower environmental impactPage 5 and thus broaden the ava ilability to more people , companies and public agencies who require these
services.

Noteworthy improvements in Fuel efficiency gains by use of such UAS s provide an a 100% decrease in
related a v i a t i o n fuel consumption

. T herefore this UAS method o f Aerial photography supports environmental efforts to severely lower any carbon footprint concer ns related to aerial video and photography. UASs provide a n excellent option which can perhaps never replace conventional manned flights but will rather c omplement the current industry and grow with it over time.

Final Operational and Safety Summary :

We will comply with all of the following condit ions and limitations should these exemption s be provided:

1) Operations will be limited to the following aircraft described in the operating documents, which is a quad

- rotor aircraft weighing 3.05 pounds: Phanto m 4 Unmanned Aircraft System.

2) The UAS will not be flown at an indicated airspeed exceeding 35 knots.

3) The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL), All altitudes reported to ATC will be in feet AGL.

4) The UAS will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times.

5) All operations will utilize a visual observer (VO). The UAS will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PI C will be able to communicate verbally at all times during the operation. The PIC will be designated before the flight and will not transfer his or her designation until the UAS is safely back on the ground. The PIC will ensure that the VO can perform the functions necessary to safely operate and supplement the actions of the PIC.

6) The operating documents and UAS manual will be accessible during UAS flight operations.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a safe and sec ure condition for flight. If the inspection reveals an unforeseen issue that could negatively affect the safe operation of the UAS, the UAS will not be operated until the required maintenance has been performed and the UAS is found to
be in a condition for safe flight. All maintenance and alterations will be properly documented in the aircraft
records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a fully functional test flight prior to resuming commercial flight operations. The PIC who conducts the functional test flight will make a mandatory entry into the UAS flight and maintenance records.

9) We will strictly follow the UAS manufacturer’s aircra ft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

10) We will carry out maintenance, inspections, and record keeping requirements, in accordance with our operating documents, which will be on site during any operat ion. Maintenance, inspection, and alterations will be noted in the aircraft records, including but not limited to total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.

11) Each UAS op erator will comply with all manufacturers’ Safety Bulletins.Page 6 12) An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered and repaired between inspections.

13) Prior to operations conduc ted for the purpose of any aerial video /photography services t he PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of
total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor
UAS.

14) Prior to operations conducted for the purpose of any aerial video /photography services the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations. The PIC will accomplish at
least 25 take

- offs and landings in the 90 day s prior to operations

15) The PIC will not operate the UAS for the purpose of any aeria l video / photography services unless the PIC has demonstrated and logged in a manner co nsistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with our operating documents, including evasive and emergency maneuvers and maintaining safe and appropriate distances from people, vessels, vehicles and structures

.
16) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC).

17) The UAS will not operate within 5 nautical miles of an airport reference point as denoted on a current
FAA

- published aeronautical chart.

18) The UAS will 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.

19) If a UAS loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documen ts. This will be achieved by presetting the GPS home base prior to flight.

20) The PIC will abort a flight in the event of unpredicted obstacles or emer gencies in accordance with

our operating documents.

21) The PIC will not begin a flight unless (conside ring wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

22) Before conducting operations, the radio frequency spectrum used for operati on and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

23) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground
Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

24) The UA will remain clear and yield the right of way to all manned aviation operations and activ ities at any given time.

25) The UAS will not be operated by the PIC from any device or vehicle in motion.

26) The UAS will not be operated over conge sted or densely populated areas w h e r e t h e u s e o f a n U A S

c o u l d p r e s e n t u n d u e h a z a r d t o n o n

- p a r t i c i p a t i n g p e r s o n s

.Page 7 27) Flight operations will be conducted at least 500 feet from all nonp articipating 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. We will ensure that nonparticipating persons re main under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determi ned that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

28) All operations will be conducted over private or controlle d

- access property with permission from the landowner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

29) Any incident, accident, or flight operati on that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

If you have questions or need any additional information, please contact us at trevor14hiner@gmail.com

or lee.hiner@frontier.com

Thank you,

Trevor Hiner
Lee Hiner Owners and Principals

Aspect Aerial Media
19904 31 st Dr SE Bothell, WA 98012