Harbor Media Group 239 West May Street Benton Harbor, Michigan 49022
May 1, 2015 U.S. Department ofTransportation DocketManagement System 1200 New Jersey Avenue, SE Washington, D.C. 20590
RE: Exemption Request Section 333 oftheFAA Reform ActofFederal Aviation Regulations (14 CFR45.23(b), 14 CFRPart 21, 14 CFR 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 119.121, 91.15l(a), 91.203 (a) and (b), 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b))
Dear Sir or Madam:
HarborMedia Group is writing pursuantto the Federal AviationAdministration (FAA) Modernization and Reform Act of20 12 and the procedures contained within 41 CFR 11 to requestthat HarborMedia Group, which utilizes small unmanned aircraft\ be exempted from the Federal Aviation Regulations (FAR) listed below so that HarborMedia Group pilotJim Stringer may operate a small lightweightunmanned aircraft system (UAS) commercially in airspace regulated by the FAA. As described herein, HarborMedia Group pilotJim Stringer is experienced in testing and flying hobby helicopters for recreational purposes. Harbor Media Group has added a hobby grade quad-copter UAS to its inventory, equipped with an internal camera ofextremely high quality and a removable 4GB micro SD card. Itshoots full HD video at 1 080p/30fps and 720p/60fps with intent for aerial videography/cinematography to enhance academic community awareness for those individuals and companies unfamiliarwith the geographical layout ofthe SouthwestMichigan area and augment real estate listing videos, following exemption and approval by the FAA. Thereby, enhancing academic research experience for the greater SouthwestMichiganregion. I (Jim Stringer) have flown small RC electric helicopters and fixed wing planes for overfour years without incident as I am committedto safety with each flight. Harbor Media Group's exemptionrequestwould permit operation oflightweight (less than Sibs), unmanned (piloted viaremote control) and comparatively inexpensive UAS(s) in tightly-controlled and limited airspace. 2 This predetermined airspace willbe in areas away from general public, airports, helipads, and vehiculartraffic for community videos and withinproperty boundaries for individual homeowner real estate listing videos and/or photos. Currently, unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe legally operate similar lightweightremote-controlled UASs. The pilot of Harbor Media Group has personally instilled safety protocols and controls3 to avoid and preventpublic hazard as well as manned aircraft hazards/catastrophe. This will actto further safety protocols exclusive to lightweightUASs specific to real estate video and photography usage as recorded flight data and otherinformation gained through permitted flight operations to share with the FAAthrough any required FAA reports to assist with future protocol and safety regulation. Granting HarborMediaGroup's request comports with the Secretary ofTransportation's and FAA Administrator's responsibilities and authority to not only integrate UASs into the national airspace system, butto "establish requirements for the safe operation of such aircraftsystems (UASs) in the nationalairspace system" under Section 333(c) ofthe Reform Act specific to the use ofUASs for real estate purposes. Further, HarborMedia Group will conduct operations in compliance with the protocols described herein or as otherwise established by the FAA.

1Appendix A - DJI Phantom Vision 2+ Quad-copter Operator Manual "Appendix B

- Southwest Michigan Regional Airport Map area with 5-mile airport radius maps 3 Appendix C - Personal Protocols and ControlHarbor Media Group Drone Exemption Application Page 2
For the reasons stated below, Harbor Media Group respectfully requests the grant ofan exemption allowing them to operate lightweight, remote-controlled UASs for academic community awareness to benefit/stimulate attraction to the greater Southwest Michigan area and to enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both ofwhich will promote local economic growth through increased employment and tax base. All with public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard.

Contact Information: Harbor Media Group, 239 West May Street, Benton Harbor, Michigan 49022 Randy Willis, Owner, 269-252-3090, hrbrphoto@gmail.com Jim Stringer, Pilot 331-725-9432,jimbostringer@gmail.com
Specific Sections ofTitle 14 ofthe Code ofFederalRegulations from which HarborMedia Group Requests Exemption From: 14 CFR 45.23(b), 14 CFR Part 21, 14 CFR 61.113(a) and (b), 91.7(a), 91.9(b)(2), 9l.l03(b), 9l.l09, 119.121, 91.151(a), 91.203 (a) and (b), 91.405(a), 91.407(a)(I), 91.409(a)(2), 9l.417(a) and (b)

The Extent ofReliefHarbor Media Group Seeks and the Reason 

### It Seeks Such Relief Harbor Media Group submits this application in accordance with the Reform Act, 112 PL 95 §§331-334 seeking relieffrom any currently applicable FARs operating to prevent HarborMedia Group's contemplated commercial, cinematic, academic, and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interestto do so. Harbor Media Group's ultra-lightweight UAS meets the definition of"small unmanned aircraft" as defined in Section 331, and, therefore, the integration ofmy ultra-lightweight UAS is expressly contemplated by the Reform Act. We would like to operate the ultra lightweight UAS prior to the time period by which the Reform Actrequires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate-related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our national airspace system. Considerations include the weight, size, speed and overall capabilities ofthe UASs, whether the UAS will be operated near airports or heavily-populated areas, and whether the UAS will be operated by line ofsight. 112 PL 95 §333(a). Each ofthese items reflect in favor ofan exemption for Harbor Media Group. Our UAS utilizes four (4) counter-rotating propellers for balance, control, and stability. Our UAS is equipped with GPS and auto-return safety technology. The UAS weighs less than five (5) lbs., which is far below the maximum 55 lb. limit, including the camera with gimbal. Harbor Media Group considers safety as foremost with each flight. Our small-unmanned aircraft is designed to hover in place via GPS and operate in less than 36 mph wind. For safety, stability and fear offinancial Joss, we will not fly in winds exceeding I0 mph. The built-in safety systems include a GPS mode, allowing our UAS to hover in place when radio controls are released. While there are three modes to choose from, we utilize Smart Mode4 for aerial videography/photography. This is the safety, most-reliable, and stable mode to prevent accident and hazards. When pilot communication is lost with the UAS, it is designed to slowly descend to thepoint oftakeoff. We do not operate the VAS near airports, hospitals/police heliports, or near areas where general public is within fifty to one-hundred (50-100) yards, depending on location, conditions, and weather. We are constantly on alert for any manned aircraft (police/medial helicopters, etc.) and are prepared to land or abort immediately to the nearest and safest ground point should a manned aircraft approach our location or we suspect manned aircraft may approach the

4 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event ofcommunication interruption between RC transmitter and UAS. Details are included in Appendix A (Owner's Manual).Harbor Media Group Drone ExemptionApplication Page 3
location. Our UAS is capable ofvertical and horizontal operations are flown only within my line ofsight ofthe operator/pilot as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three and seven (3-7) minutes with an altitude thatwill not exceed one-hundred fifty (150) feet. Harbor Media Group utilizes a fresh, fully-charged battery with each flight as a safetyprecaution; full flight time is limited to 25 minutes each battery (as tested). We do not operate the UAS at or below manufacturerrecommended minimum charge levels for operation and preferto remain well within a safe operating range to insure adequate communication betweenradio control and UAS to eliminatepotential for crash, loss ofcontrol orhazard. Reserve batteries are on-hand with each exercise to insure replacement for sufficient safe level ofoperation. We do not believe in taking risks that may cause a crash that could create a hazard to the public, property ormanned aircraft and have no desire to lose an investment. We have clocked numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics ofthis specific UAS's performance under different temperature and weather conditions. We also practice computerized flight simulations to maintain adequate skills and response reflex time. All ofthis is done to insure safety at all times. Harbor Media Group is extremely cautious when operating the UAS or otherultra lightweight unmanned aircraft and will not "create a hazard to users ofthe national airspace system orthe public" (112 PL 95 §333(b)). Given the small size and weight ofthe UAS, it falls well within Congress' contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Harbor Media Group's UAS- used in hobby flight- has a demonstrated safetyrecord and does notpose any threat to the general public or national security.



### How HarborMedia Group's Request Will Benefit the Public As a Whole: Aerial videography for geographical awareness and real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budgetreal estate companies and the average homeowner, the expense ofsuch aerial videography is cost-prohibitive. Only large companies and high-end realtors or luxury homeowners can afford to absorb the expense, depriving the non-luxury and lower budgethomeowner and realtor from a valuable marketing tool. Congress has already proclaimed that it is in the public's interestto integrate commercially flown UASs into the national airspace system by passing the Reform Act. Furthermore, the Michigan Legislature passed HCR 165 (sponsored by the owner ofEagle-Eye Drone Service) in December 2013, supportingMichigan's Advanced Aerial Systems Consortium as one ofthe test sites designated by the FAA. Granting Harbor Media Group's exemption request furthers the public interestthrough academic/ visual awareness ofthe geographical benefits in and around the greater SouthwestMichigan area. Ourultra lightweight UAS crashing is battery-powered and creates no emission that can harm the environment. The consequence ofour ultra lightweight UAS crashing is far less than a full-size helicopter or fixed-wing aircraft, which are heavy, contain combustible fuel, and can cause catastrophic devastation to the public. The public's interest is furthered by minimizing ecological and crash threats bypermitting aerial video/photo capture through the battery-operated, ultra lightweight UAS. Permitting HarborMedia Group to immediately fly within national airspace furthers economic growth. Granting our exemption requests substantially furthers the economic impactfor the SouthwestMichigan community for companies looking to relocate or build in the area as well as individuals lookingto relocate for careers advancementthrough academic and geographical awareness. Both serve as stimulus to the community.



### Reasons Why HarborMedia Group's Exemption Will Not AdverselyAffect Safety orHow theExemption Will Provide Level ofSafety At LeastEqual to ExistingRule: Harbor Media Group's exemption will not adversely affect safety. Forthe reasons stated, permitting Harbor Media Group to log more flight time in FAA-controlled airspace with communication will allow us to contribute to the innovation and implementation ofnew, novel and undiscovered safety protocols for Realtors that can be embraced by the National Association ofRealtors, Michigan Association ofRealtors, and local realtor associations

5 http://www.legislature.mi.gov/documents/2013-2014/concurrentresolutionadopted/house/pdf/2013-HACRH0016.pdfHarbor Media Group Drone Exemption Application Page 4
for development in cooperation with the FAA. IN addition, Harbor Media Group submits the following representations ofenhancements to current aerial videography and photography for real estate:



### •

• • Our UAS weights less than 4 lbs. complete with a small, ultra lightweight, high-quality HD camera. We only operate the UAS below 200 feet6
, which is well-within the 400-footpermissible ceiling set by the FAA Modernization and Reform Act of2012. Our UAS only operates for 5-l0 minutes each flight. We land the UAS prior to manufacturer-recommended minimum battery power levels. We pilot the UAS through remote control only by line ofsight. The UAS has a GPS flight safety feature, whereby it hovers and slowly lands ifcommunication with the remote control pilot is lost. We actively analyze flight data and other sources ofinformation to constantly update and enhance safety protocols. We only operate in reasonably-safe environments that are strictly controlled and are away from power lines, elevated lines, airports and active-populated area. We conduct extensive preflight inspections and protocol during which safety carries primary importance

. We always obtain all necessary permission before operation

. We have procedures in place to abort flights in the events ofsafety breaches or potential danger. Harbor Media Group's safety protocols provide a level ofsafety that is equal to or exceed existing rules. Itis important to note that absent the integration ofcommercial UAS into our national airspace system, helicopters were the primary means ofaerial video and photography for community awareness and real estate. While the safety record ofsuch helicopters as remarkably astounding, there has been local incident involving loss oflife as well as extensive property damage; it is far safer to operate a battery-powered lightweight UAS. First, the potential loss of life is diminished because our UAS carries no people and will be operated in specific areas away from the mass population. Second, there is no fuel onboard the UAS, limiting the potential for fire or explosions. Third, the small size and extreme maneuverability ofthe UAS allows Harbor Media Group to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, the UAS need not be so close to objects it is focused on through technology and use ofpost-editing software. Accordingly, our UAS has been experimentally-operated for familiarization and competency and will continue to be operated at and above current safety levels.

A Summary the FAA MayPublish in the Federal Register: A. 14 CFR 21 and 14 CFR 91: Airworthiness Certificates, Manuals and Similar 14 CFR 21, Subpart H, "Airworthiness Certificates" sets forth requirements for procurement ofnecessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of Harbor Media Group's UAS permits exemption from Part21 because the UAS meets and exceeds an equivalent level ofsafety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under Act49 USC§ 4470l(f) and Section 333 ofthe Reform Act. Both pieces oflegislation permitthe FAA to exempt UASs from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability, and proximity to areas, such as airports and dense populations. Harbor Media Group's current and projected UASs meet or exceed each ofthe elements. 14 CFR 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certification will be applicable in the form contemplated by the FAR, this regulation is not applicable. 14 CFR § 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there will not be pilots or passengers onboard the UAS and given the size ofthe UAS, this regulation is not applicable. An equivalent level ofsafety will be achieved by maintaining a safety/flight manual delineating areawhere safety can be defined?The FAA

6 DJI Phantom Vision 2+ quad-copter altitude ceiling is 147feet when flow in Smart Mode. See Appendix A (Operator Manual). 7 Appendix D- Safety/Flight ManualHarbor Media Group Drone Exemption Application Page 5
has previously issued exemptions to this regulation in Exemption# 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10602, 10700 and 32827. 14 CFR 

### § 91.121 regarding altimeter settings is not applicable insofar as ourUAS utilizes electronic global positioning systems (GPS) with a barometric sensor. 14 CFR 

### § 91.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are not applicable for the samereasons as described above. The equivalent level ofsafety will be achieved by maintaining any such required certifications and registration the UAS pilot/ownerJames Stringer. B. 14 CFR45.23: Marking ofthe Aircraft Applicable Codes ofFederal Regulation require aircraftto be marked according to certain specifications. Our UAS are- by definition- unmanned. They, therefore, do nothave a cabin, cockpit, orpilot station on whichto mark certain words or phrases. Further, two-inch lettering is difficultto place on a small aircraftwith dimensions smallerthat minimal lettering requirement. Regardless, we will mark the UAS in the largest possible lettering with the word "Experimental" on its fuselage as required by 14 CFR 

### § 45.29(f) so thatthe pilot or anyone assisting as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemption# 8738, 10167, 10167A, and 10700. C. 14 CR 

### § 61.113: Private Pilot Privileges and Limitations, PIC Pursuant to 14 CFR 

### § 61.113(a) and (b), private pilots are limited to noncommercial operations. HarborMedia Group can achieve an equivalent level ofsafety as achieved by currentregulations because ourUAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not insure remote control piloting skills. The risks attended to the operation ofthe UAS is far less than the risk levels inherentin the commercial activities outlined in 14 CFR 

### § 61, et. seq. Thus, allowing Harbor Media Group to operatetheirUAS will meet and exceed current safety levels in relation to 14 CFR 61.113(a) and (b), D. 14 CFR 

### § 91.119: Minimum Safe Altitudes 14 CFR 

### § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. Itallows helicopters to be operated at lower altitudes in certain conditions. Our UAS will never operate at an altitude greaterthan 200 AGL, safely below the standard of400 AGL. Harbor Media Group will however operate the UAS in safe areas away from publie and traffic, providing a level ofsafety at least equivalentto or below minimum safe altitudes. Given the size, weight, maneuverability and speed ofmy UAS, an equivalent or higher level ofsafety will be achieved. E. 14 CR 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b): Maintenance Inspections The above-cited regulations require aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph c ofthis section have discrepancies repaired as prescribed in part43 ofthis chapter

..." These regulations only apply to aircraft with an airworthiness certificate. Theywill not, therefore, apply to Harbor Media Group's UAS. However, as a safety precaution, we inspectthe UAS before and after each flight. A Summary the FAA may public in the Federal Register: 14 CFR 21 Subpart H "Airworthiness Certificates' sets forth requirements for procurement ofnecessary airworthiness certificates in relation to FAR91.203(a)(1). The size, weight and enclosed operational area ofthe UAS permits exemption from Part 21 because HarborMedia Groups' UAS meets an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorizedto exempt aircraft form the airworthiness certificate requirement under both the 49 USC 44701(f) and Section 333 ofthe Reform Act. Bothpieces of legislation permitthe FAAto exemptUASs from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. TheUAS meets or exceeds each ofthe elements. 14 CFR91.7(a) prohibits the operation ofan aircraftwith an airworthiness certificate. As no such certificate will be applicable in the form contemplatedby the FARs, this regulation is not applicable. 14 CFR 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As thee are no pilots orpassengers and given the size ofthe UASs, this regulation is not applicable. An equivalent level ofsafety will be achieved by maintaining this manual. The FAA has previously issued exemptions to this regulation in Exemption# 8607, 8737, 8738, 9299, 9299A, 9565, 95658, and 10167. As the maintenance program will involve regular software updates and curative measures for any damaged hardware, an equivalent level ofsafety will be achieved.HarborMedia Group Drone ExemptionApplication Page 6
In summary, Harbor Media Group seeks an exemption from the following regulations: 14 CFR21, subpart H, 13 CFR45.23(b), 13 CFR 61.113(a) and (b), 14 CFR 91.7(a), 14 CFR91.9(b)(2), 14 CFR91.103(b), 13 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR91.203(a) and (b), 14 CFR91.405(a), 14 CFR 91.407(a)(l), 14 CFR 91.409(a)(2), 14 CFR 91.409(a)(2), and 14 CFR 91.417(a) and (b) to commercially operate a small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations and to develop economic platforms for real estate to enhance the experience ofthose seeking to relocate to the Southwest Michigan area. Currently, area awareness and real estate aerial photography/videography relies primarily on the use oflarger aircraft running on combustible fuel, posing potential risk to the public. Granting HarborMedia Group's request for exemption will reduce currentrisk levels and, thereby, enhance safety. TheUAS craft does not contain potentially-explosive fuel and is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, we operate at lower altitudes and in controlled airspace, eliminating potential public risk involved in flying to and from established air fields. Harbor Media Group has been informally analyzing flight information and will compile safety protocols and the implementation ofa flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection ofinformation shared with the FAA will enhancethe FAA's internal efforts to establish protocols for compliance with the FAA Modernization and Reform Actof2012. There are no personnel onboard the UAS, and the likelihood ofdeath or seriously bodily injury is significantly diminished as a result. HarborMedia Group's operation ofthe UAS (which weighs less than 5 lbs. and will travel at lower speeds withinthe limited areas) will provide an equivalent level ofsafety as that achieved under currentFARs. Accordingly, HarborMedia Group respectfully requests thatthe FAA grant our exemptionrequest. We are willing to cooperate in sharing information to the benefit ofthe FAA, the continuing safety ofmanned aircraft, and the general public at-large.
Specifics ofthe UAS: UAV/UAS/UA Clarification8

- The UAVIUAS/UA which HarborMedia Group ("Petitioner") will be operating is a DJIPhantom 2 Vision+, referred hereafter as "Phantom". The inherent safety features, sophistication, programmability, GPS navigation, return home capability, airport vicinity no-fly feature and restricted altitude feature combined with differentiating radio frequency (rt) for aircraft controller/receiver and the cameramakes this a much saferUAV for the purposes ofthis petition. This is a hobby-grade, radio-controlled UAV thathas the capacity for software upgrades and is light (weighing less than 3 lbs. including battery and camera). Incorporated into the programming of the Phantom is an automatic return home feature that directs the craftback to point oftakeoffshouldcommunication with the transmitter be lost. The Phantom has a cruising speed of20MPHwith a maximum speed of36MPH and a maximum flight time of25 minutes. Italso has a gross weight of2.86 lbs. The Phantom has an additional communication link between the camera and craft on a different rffor a smartphone connection, allowing the operator/pilot in command (PIC) to monitor battery level, altitude (AGL), distance from PIC< camera imagery, and control camera angle. The software for the Phantom allows the operator/PIC to set maximum altitude AGL for each flight with customization offlights to no higher than 100ft., 150ft. or 250ft. AGL for example. The 400ftmaximum AGL can be programmed into the UAV's software pre-flightto insure compliance with FAA standards, adding to the safety capabilities ofthe UAV. This UAV is programmed to remain in positionwhen controls are released, maintaining altitude and GPS location. The Phantom has an altitude and radar monitoring function that allows the operator more precise determination ofheight and direction offlight and distance from the operator/PIC. The operator/PIC can monitor GPS lock status while UAV is in flight with the ability to anticipate loss ofGPS locking so the operator/PIC can land the UAV as a precaution. The Phantom has a 2.4 ghz transmitter/controller/receiverrfformanaging flight with a 5.8 ghzrf transmitter/received for video/photography functions that eliminatedtherfconflictthat is experienced witthe Blade 350 QX and is by far the safer ofthe two when consideringpublic and NAS safety. Consideringthe programmability and safety features ofthis UAV, it serves as the best option to protectthe public and NAS for the purposes ofthis petition.

8 The best explanation ofthe Phantom's sophistication and capabilities can be observed through a series of manufacturer videos; it maintains all capabilities defined in the video. http://www.dii.com/productlphantom-2- vision-plusHarbor Media Group Drone ExemptionApplication Page 7
The Harbor Media Group petition is for UAV operation without pilot, passengers orproperty onboard. The UAV is a sophisticated hobby-grade quad copterwith a gross weight ofless than 3 lbs. Aerial video/photography operations for this petition will provide serve for those businesses, transferees, retirees and others considering relocating to the SouthwestMichigan region who are unfamiliarwiththe geographical characteristics, communities, services and other benefits ofthe area. Aerial video/photography operations for private property owners will be aided with an enhanced perspective ofthe characteristics, amenities and benefits a private property has that cannot be displayed through ground level video/photography. HarborMedia Group charges no additional fees for ground level video/photography. Aerial video/photography represents a small portion ofvideos and photos currently offered at ground level for the community as well as private properties marked for sale. Aerial video/photography is an enhancementto videos/photography already offeredto homeowners and the public. In most cases, aerial video will represent4-20 seconds ofa 2-3 minutes video. Harbor Media Group is using a UAC thathas the capability for taking off/landing at a single point (identical to a helicopter). No runways, takeoffapparatuses, orroutes that need to be flown to the areas being photographed/records are required, allowing for a more reduced and confined area offlight. Homeowner consent in writing for aerial video/photography will be obtained priorto flight. Signs will be posted cautioning anyone within the vicinity to remain back at a minimum of200 ft. Observer(s) to assist and warn/advice the PIC will be utilized where spectators may be within 500ft. ofthe flight area. To alleviate additional privacy concerns, petitionerhas the ability to coverup areas in movie postproduction by shading out objects in the immediate vicinity. The single UAV utilized in this petition is a hobby-grade quad copterthat does not require an airman certificate for noncommercial fight involving less restrictive/less regulated flight. UA V flight competency canbe verified/obtained through AMA standards/procedures as well as downloadingthe flight datafrom the onboard data logger. The motors, rotors, propellers, body/frame, landing pads, etc. for the UAVutilized in this petition are not complicated. Engineering and design allows layman maintenance. Recording partreplacement for this UA V may prove redundant due to the simplicity ofthe craft. While the petitionerrequestwaiver/exemption for maintenance records, it would be understandable iftheFAA requires such data for its rule-making process. However, preflight inspection for cracks, damage or other physical conditions thathamper safe flight is a reasonable expectation as well as post flight inspection may aid in identifying flight conditions thatmay cause stress to propellers, landing gear, etc. Thorough inspection ofUAV shall be conducted and flight response tested should a hard landing orcrash occur. Insuring that the UAC can operate in a safe mannerbefore conducting any further video/photography. Petitioner requests waiver/exemptionfor markings due to the small size ofthe fuselage ofthe Phantom 2 Vision+.Petitioner requests modification, waver or exemption and clarification within reason concerning section 91.119 on the prohibition offlight in congested areas. Such restriction puts homeowners in subdivisions at a disadvantage by limited enhanced marketing oftheir homes, thereby discriminating againstthem. Vertical takeoff/landing while video recording orphotographing can allow an enhanced perspective for view or proximity of mountains, golfcourses, manmade lakes, or other attractions not possible through ground level recording or photography. Petitioner requests waiver for this condition to allow reasonable and responsible aerial video/photography in congested areas ofsubdivisions and neighborhoods. In cases where altitude within airports is an issue, aerial video can be achieved under 100 ft. In compliance with Section 90.151(a), the Phantom is a battery-operatedUAV/UAS withbattery level monitoring capability. Fully-charged battery flight time is rated at 25 minutes with videos/photos taking much less time to record. The operator/PIC is warned whenbattery level is low. Petitioner requests waiver/exemption from Section 91.203(a) since the Phantom is a hobby-grade UAV /UAS that should not require an airworthiness or registration certificate. Posting a special flight authorization would not be possible since the Phantom has no cabin and is not large enough to carry a certificate. However, a special flight authorization can be maintainedby the operator to make available upon request.

DJI Phantom 2 Vision+ Serial Number: 1. Height limitation setfor maximum of300 ft. AGL

## " 2. Radius distance from controller set for maximum of 1000 ft. 3. Both to aid in VLOS Harbor Media Group Drone ExemptionApplication Page 8

4. Flight testing at the RIC air park has proven that due to UAS size ofthe Phantom 2 Vision+, firmware programmed for maximum 300 ft. AGL and 1000 distance are limited distance for maintaining VSOL without assistance ofbinoculars or other devices. Most ofthe intended operation will only require ranges of20 to 100 AGL and less than 200 ft. lateral distance from PIC. Limited stated distance for VSOL will be rare, ifever needed. Current Firmware Upgrades for 5. Main Controller 6. GPS 7. Received 8. Battery 9. Zen IMU Petitioner would like to seek a reasonable exemption with restriction solely to UAS operation at AGL below 300 feet with distance offlight no greaterthan 1000 ft. Currently, there are no provisions within the FAA for governing UAS, such as the DJI Phantom 2 Vision+ for hobby or commercial use in Southwestern Michigan. With Phantom 2 Vision+ alone, sales have been 

### "exponentially higher than the 7,500 in 5-years estimate that the FAAput forward ayearago... "UAS potentially being flown without guidelines by unfamiliar and untrained individuals not belonging to professional organizations like the AMAM pose a threat to the nAS, the public and responsible parties like the petitioner. Thank you for your consideration, and please let us know ifyou have any questions regarding this application. 

# 97/JI '1/1 Randy Willis Stringer Owner, Harbor Media Group Ha<boc Mod•aGwup
Appendices DJI Phantom Vision 2+ Owners Manual • A Available at http://download.djiinnovations.com/downloads/phantom

_2

_vision _plus/en/Phantom_2_ Vision_Plus_ User_ Manual_ v 1.8

_en.pdf

• B Southwest Regional Airport Vicinity and SNM Circle

• C Protocols and Controls for Aerial Community and Real Estate Videos

• D Safety Flight Manual (ChecklistFormat)

• E Caution Sign Placard

• F Phantom Flying Flowchart Vl.O (Simplified Version)

### Drone ExemptionApplication- Appendixes (1)


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### 5km Drone Exemption Application -Appendixes (2) 

# AppendixB SouthwestRegional Airport Vicinity and SNM Circle



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### Drone ExemptionApplication -Appendixes (3) 

## Appendix C Protocols and Controls for Aerial Community and Real Estate Videos Safety for public on the ground as well as manned aircraft above is an essential and utmost considerationfor aerial videos and photography. As such, safety protocols and controls mustbe implemented through pre-flightpreparation and during flight. Pre-RightProtocol Check batteries with voltage meter to insurefully charged and ready for use. Inspectbatteries for damage orleakage that may affect proper operation. Inspect propellers for cracks,chips ordamage that may cause sudden loss ofpropulsion orunmanageable/uncontrolled flight. Check weather forecasts for wind advisory or otherconditions that my impactflight. Consultfive (5) mile radius map for airport vicinity. Contactrespective airport to advise ofestimatedflight time, estimatedflight duration, estimated elevation offlight, and any otherpertinentinformation. Inspect flight area for Vicinity ofpublic safety helipads/heliports Vicinity ofmedical helipads/heliports Vicinity oflight poles Vicinity or utility wires Vicinity oftrees Rocks ofbirds that may cause interference and potential flight impact Vicinity ofany elevated obstructions that may posepotential flight hazard Vicinity ofroadways with moderate to heavy traffic that can be distracted Public gatherings that may attract viewers Optional point ofcontrol for best visual site ofUAS while in flight Takeoff/Landing Inspect area for best and safest point oftakeoffand landing Ifin a subdivision or area thatis within 150feet ofa residential street,post warning sign(s)/stand(s) "Attention Aerial Photography In Progress- Remain Back 150 Feet" Right Protocol Takeoffand landfrom same location Remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficientto acquire desired results Remain preparedfor emergency landing at all times Pay attention to flight time. Ifpossible, set a timer as a safety alert Land UAS and shut down propulsion immediately following landing
Post flight: Emergency or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event Manned aircraft is heard or seen in vicinity offlight There is a public gathering within established safety boundary wanting to observeflight o pilotis being distracted from focusing on flight and safety Sudden change in weather (wind bursts) Sudden increase in vehicular traffic in vicinity offlight Birds enter into proximity offlight Any sudden unsafe event that can cause collision, distraction orinterruption ofcontrol

### Drone Exemption Application -Appendixes (4) 

# Appendix D Safety FlightManual (ChecklistFormat)



# Phantom 2 Vision 

# + Mission Checklists

Arrival Checklist 

### 1. If day and operating outof .back of vehicle, pointvehicle :into sun. 

### 2. Remove case and place on level surface. 3. 

### Check distance to nearest airport and/or controlled airspace using smartphone or tablet app. 4. If required, use VHF aviation transceiver. to contacttower offield if closerthan 

### 5 NM. 5. Inform tower 

### I CTAF of UAS ops, .location, and max heightof flight



### 2. Router

- On 

### 3. Transmitter- On 

### 4. Toggle Switches

- Full Up 5. 

### Video Monitor- On 

### 6. Remove UAS from case. 7. Gimbal Lock & Lens Cap- Removed 8. Micro-SO card- Inserted. 9. UAS Battery- Inserted 10. Place UAS in clear and safe launch and recovery position if it returns to home. 11. UAS Battery

- On 12. Wifi Connection to Monitor- Vermed 13. DJI Application

- Load 14. OJI application- Connect to Camera 15. SO Card- Format 16. Camera- Full Up 17. Satellite Connections- Verified 18. Charge Levels- Safefor Flight 19. Video Recording

- Start 20. Takeoff f·eet above the ground to confirm UAS is under control. 2. All sticks operate correctlywhile in hover -Verified



### 2. Video Recorder- Stop 

### 3. Landing Zone- Clear 

### I Safe



### 1_ Battery

- Remove & Replace 

### 2. Wifi Connection to Monitor

- Verified 

### 3_ OJl application- Connect to Camera 

### 4. Takeoff 

### Endof Ops 

### Checklist 

### 1 _ Battery

- Off 

### 2. Transmitter- Off 

### 3_ Router

- Off 

### 4_ NotifyTower/CTAF

- End ofOps

Place Caution Placards 2C•D feetfrom ioJ:ation. 

### Weather Surtace Observation Sky:.

__________ _ Vsby:

_________ _ Temp:

_________ _ 

### Wind:

__________ _ Gusts:.

__________ __ Weather atAltitude: Flight Level Winds:

_____ _ Forecast: Clr, Set, Bkn,Ovc (Circ!e one) 

### Pcpn:.

_______ _ Winds:.

______ _

### Drone ExemptionApplication- Appendixes (5) 

## AppendixE CautionSign Placard 

# Caution Aerial PhotographyIn Progress 

# Remain Back200 Feet

### Drone Exemption Application- Appendixes (6) 

# AppendixF Phantom Flying Flowchart VI.O (Simplified Version)

Switch on tile transmitter. and :then power on the PI-'J\NTOM.

Second Level 041114111$411$0019 Protection Alert &Heq;1ht**Des~nt** FailSafe LED: Blink Yellow --------111-1 Qu:clly ()1!>0000000

LED:Red+ Green+Yellow Corrpass ErrorTeo Eieg ------..,. 

# t-------111-( LED:Red+Yellaw).....

.... If Red LED appears in the lastfour 

# "'--------+1green flashes, lhe**auto~** system CJinnat wan.

1npcr.::m:: PHANTOM s**T!O\l~d** aTI:.::r**~:Y?W'E'f D~for~** **11~·'*** rnc:ors st:arHJp <

{f s :s:at::)na-). nn please c!J the

Part means normal procedlures:**--~::.** means reg•J!ar siWaticn. mear.s SE<Ieata!Oie orpcssitle situation. T;:.(t tells the deta:l:s. R-.,d Part me;ms possible**abnom~al** situation. Pal'! is possible in normal or abnormal sirua'licn, reqwe you to coniirm by lhe T**;::~:** far details. Part is the condition oflhe normal situation. Pur;Xe Part is the oond.tion: afthe abnormal s:tuation.

### Drone Exemption Application- Appendixes (1)



# AppendixA DJI PhantomVision 2+ Owners Manualhttpjfdownload.dji**innovC1tions,<::om/downJoqJJS/phqntOJIL2_vision_pl.tJs/~nlPb<lJ1tQDL2_VisJon_PlYsJJs~LM<lDJJ<lLYl,8_~n,p** 

## dJ (Instead ofinsertingpdfintothis document, linkis provided for immediateviewingand download.)

### Drone ExemptionApplication

- Appendixes (2) 

# AppendixB Southwest Regional Airport Vicinity and SNM Circle



## Satellite



# ..**':eo~om~·irw~}** ,.,_"-' ,-,



# ...

# ::::r:~~ Wat«9iit

Bainbridge

## Twrp

5km

### Drone Exemption Application -Appendixes (3) 

# Appendix C Protocols and Controls for Aerial Community and Real Estate Videos Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre-flight preparation and during flight. Pre-Flight Protocol Check batteries with voltage meter to insure fully charged and ready for use. Inspectbatteriesfor damage or leakage that may affect proper operation. Inspect propellers for cracks,chips or damage that may cause sudden loss ofpropulsion orunmanageable/uncontrolledflight. Check weather forecasts for wind advisory orotherconditions that my impactflight. Consult five (5) mile radius map for airport vicinity. Contact respective airport to advise ofestimatedflight time, estimated flight duration, estimated elevation offlight, and any other pertinent information. Inspect flight area for • Vicinity ofpublic safety helipads/heliports Vicinity ofmedical helipads/heliports Vicinity oflight poles Vicinity or utility wires Vicinity oftrees Flocks ofbirds that may cause interference and potential flight impact Vicinity ofany elevated obstructions that may pose potential flight hazard Vicinity ofroadways with moderate to heavy traffic that can be distracted Public gatherings that may attract viewers Optional point ofcontrol for best visual site ofUAS while in flight Takeoff/Landing Inspect area for best and safest point oftakeoffand landing Ifin a subdivision orarea that is within 150feet ofa residential street, post warning sign(s)/stand(s) "Attention Aerial Photography In Progress- Remain Back 150 Feet" Flight Protocol Takeoffand land from same location Remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distract the remote control pilotrestrictflight to minimal elevation sufficient to acquire desired results Remain prepared for emergency landing at all times Pay attention to t1ight time. Ifpossible, set a timer as a safety alert Land UAS and shut down propulsion immediately following landing
Post flight: Emergency or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event Manned aircraft is heard or seen in vicinity offlight There is a public gathering within established safety boundary wanting to observe flight o pilot is being distractedfrom focusing on flight and safety Sudden change in weather (wind bursts) Sudden increase in vehicular traffic in vicinity offlight Birds enter into proximity oft1ight Any sudden unsafe event that can cause collision, distraction or interruption ofcontrol

### Drone ExemptionApplication -Appendixes (4) 

# AppendixD SafetyFlightManual (ChecklistFormat)



# Phantom 2 Vision 

# + Mission Checkllists

Arrival Checklist 1. If day and operating· outof backof vehicle, pointvehicle into sun_ 2. Remove case and place on level surface_ 

### 3. Check distance to nearestairportand/or controlled airspace using smartphone or tablet app. 4. If required, use VHF aviation transceiver. to contacttoweroffield ifclos.ec than 

### 5 NM. 

### 5_ Inform tower 

### I CTAFof UAS ops. location. and max heightofflight

### ~;?t;3tGI 1 . 

### Remove transmitter_ 2. Router

- On 

### 3. Transmitter- On 

### 4_ Toggle Switches- Full Up 5. Video Monitor- On 6. 

### Remove UAS from case. 

### 7 _ Gimbal Lock 

### & Lens Cap

- Removed 8. 

### Micro-SO card- Inserted. 9. 

### UAS Battery -Inserted 1

# o_ Place UAS in clearand safe launch and recovery position if 

### it returns to home. 11. UAS Battery- On 12. Wifi Connection to Monitor

- Verified 13. 

### DJI Application

- Load 

### 14. DJI application- Connect to Camera 

### 15. SD Card- Format 16. Camera

- Full Up 17. 

### Satellite Connections- Vemied 

### 18. Charge Levels- Safefor Flight 19. Video Recording

- Start 20.Takeoff 

# !ifilDmm:rm;m;arm• 1. Hover appmximatelyten feet above the ground to confirm UAS is undercontrol_ 

### 2

_ All sticks operate correctlywhile in hover -Verified 

# ;;uamnt.u;t!q;masraa 1. Camera

- Full Up 

### 2. Video Recorder

- Stop 

### 3. Landing Zone

- Clear

### I Safe



### 1. Battery

- Remove

### & Replace 

### 2. Wifi Connection to Monitor

- Verified 

### 3. DJI application- 

## Connect to Camera 

### 4. Takeoff 

## Endpf\1Jps,(;he<:.ldist· 1

_ Battery

- Off 

### 2. Transmitter- Off 

### 3. Router- Off 4. NotifyTower/CTAF

- End ofOps

Plar::e Caution Placards200feetfrom location. 

## Weather
Surface Observation Sky:

_________ _ Vsby:

_________ _ Temp:

__________ _ Wind:.

__________ _ Gusts:

__________ _ WeatheratAltitude: FlightLevel Winds:.

_____ _ Forecast: Clr, Set, Bkn}'Ovc (Circleone) 

## Pcpn:.

_______ _ Winds:

______ _

### Drone Exemption Application- Appendixes (5) 

# AppendixE CautionSign Placard 

# Caution Aerial PhotographyInProgress 

# Remain Back200 Feet

### L.Eo: 81iilk'1 Green Quctly

Record 1m:

forward**~~.~icn.** 

### Drone Exemption Application- Appendixes 

### (6) 

# AppendixF PhantomFlyingFlowchartVI.O (SimplifiedVersion)

lmporunt ·s mcved**amr~r•** ;,•;a bil!l'l>!'e tllo?**~start-\lp** mat ll©l'lllal. If .s s:atkmary 01'1

### me**~UM, ple~**  try

### me IML.**~** .: wlibrnuoo.

' ?:art means**norma~** pwcedl.ll't!5:**--~means** 

### ....siuation.

- - II> meansseleetable orposstie**situ~ion.** tellsthedetail, Ril!d Part means possibleabnormal situation. Part is**~e** innorma! ori1lmolmaJ situation.**req:~~.We** you toccmfiml bylheTex! fordetails. Slue Part is theconditionoflhe norma! situation.**Pu~** Part is the condition ofthe amormal situati©l'l.