December 21, 20 15

Joel Smith Comprehensive Media, Inc.

214 Overlook Circle

Suite 180 Brentwood, TN 37027 jsmith@comprehensivemedia.com

615.866.3150

Federal Aviation Administration:

Comprehensive Media, Inc. and its President, Joel Smith, hereinafter referred to collectively as ( “ CMI ” ), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that CMI , an owner and operator of small

unman ned aircraft, be exempted from the Federal Aviation Regulations ( “ FARs ” ) listed below so that CMI may operate a small ultra light weight unmanned aircraft system ( “ UAS ” ) commercially in airspace regulated by the Federal Aviation Administration ( “ FAA ” ) in

a ccordance with FAA UAS Regulations & Policies.

CMI would like to formally submit itself all of its UAS pilots for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C .F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate a Phantom 2 Vision+ UAS

manuf actured by DJI, which will be equipped with detachable cameras and will be transported in

proper storage.

This proposed exemption would allow CMI operation of unmanned aircraft systems (UAS) for the purpose of aerial videography/photography as a service to the public/business interests. As found in exemption No. 11138 (Trudeau), the FAA recently approved similar use of DJI UAS. These devices were selected because they have proven to have reliable flying capabilities managed by GPS stabilized flight and h overing, ground detection, GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home, self tightening propellers and no fly

zones feature.This will act to further safety protocols exclusive to lightweight UAS ’ s specific to video a nd photography usage as CMI record s flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assists with future protocol and safety regulations. Specific section or sections of 14 CFR which I seek relief and

the reason I seek relief: 14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the aircrafts to be utilized by CMI an exemption from Part 21 meets the requirements of an equi valent level of safety under Part 11 and Section 333 of the

reform Act.

In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed wi ll be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UAs will not have a cabin, cockpit, pilot station, fuselag e, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges a nd limitations: Pilot in command The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemp tions to this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes CMI will ensure that UAS do not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations bef ore hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91. 151(a)(1): Fuel Requirements for flight in VFR conditions The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than

25 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil ai rcraft: Certifications Required

- Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS.

CMI will alway s fly safely while having the manuals of the DJI Phantom 2 Vision+ . 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspectio ns & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airw orthiness certificate. However

, CMI will perform preflight inspections of the UAS before each flight as outlined in the operating

documents. CMI will also follow manufacturer recommendations from said operating

documents. Also as mentioned in the Trudeau e xemption, exemption No.11138: “ Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more offuel. The petitioner ’ s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located

from the aircraft. The l imited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS] for the proposed operation. ”

CMI is seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 9 1.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b) With the exemptions

of the mentioned rules CMI will be seeking to make drone photography/videography services available to the public. Alternatively the public h as looked to use helicopters and aircraft to achieve what CMI can offer in a safer, more cost efficient manner. By not using combustible fuel, flying at safe heights and strictly following the usage recommendations from DJI. These include but are not limit ed to:

● Flying the following UAS Safely

○ DJI Phantom 2 Vision+

● Flying below 400 feet

● Proper visual inspection of UAS before flights

● Keeping mentioned UAS in visual sight at all times when in operation

● Using an observer to assist if needed

● Remain ing well clear of and do not interfere with manned aircraft operations, and

avoid other aircraft and obstacles at all times

● Not intentionally fly over unprotected persons or moving vehicles

● Contact ing the airport or control tower before flyin g within 5 miles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensuring the operating environment is safe

● Not flying over sensitive infrastruct ure or property such as power stations, water treatment facilities, correctional facilities, etc.

● Check ing and follow ing all local laws and ordinances before flying over private

property

● N ot conduct ing surveillance or photograph persons in areas wher e there is an expectation of privacy without the individual's permission.

Kind regards,

Joel Smith **Comprehensive Media, Inc.** 214 Overlook Circle, Suite 180 Brentwood, TN 37027 jsmith@comprehensivemedia.com

615.866.3150