Re:Exemption request pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations from: 14CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14CFR 91.9(b)(2); 14CFR 91.103; 14CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14CFR 91.203(a) and (b);14 CFR 91.405(a); 14 CFR 91.407(a) (1) 14 CFR 91.91.409 (a) (1) and (2); 14 CFR 91.417(a) and (b) Dear Siror Madam, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "ReformAct") and 14 CFR Part 11, Johnny Hyman, operator ofan UnmannedAircraft System (UAS), hereby applies for an exemption from the listed FederalAviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein as may be established by the FAA as required by Section333. I am requesting this exemption for one 30 Robotics Solo to be used for my aerial photography business. I additionally request this exemption be granted for use anywhere within US airspace system and not confined to a limited geographic area ofoperation. • Commercial operation ofa UAS, as described herein, which are equipped with a camera and sensors, would

operate in the following manner: • Aerial photography and/orvideo for public and/or private use including real estate, architecture, land

surveying, engineering and other related professional activities. • Aerial video and/or photography for photography for public and/or private use including television, public

events, cinematography and news gathering. • Aerial inspection/photography of residential/commercial structures undercontract with the owners or local

government authority. • Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to

electrical power lines, wind turbines, and cell towers. • Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of

an emergency or natural disaster only when the local authorities orgovernment has requested it by contract or donation. As described fully below, the requested exemption would permitthe operation ofa UAS undercontrolled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "...establish requirements forthe safe operation ofsuch aircraft systems in the NationalAirspace System." The name and address ofthe applicant is: Johnny Hyman Eye in the Sky Productions 3108 Cypress Mill Rd. Apt. 42 Brunswick, Georgia 31525 johnnyhyman@ymail.com 904-962-8700Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23(b) 14 CFR 91.7(a) 14 CFR 91.9(b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14CFR91.121 14 CFR 91.151(a) 14 CFR 91.203(a) and (b) 14 CFR 91.405(a) 14 CFR 91.407(a) (1) 14 CFR 91.409(a) (2) 14 CFR 91.417(a) and (b) Eye in the Sky Productions will be operating one 3D Robotics aircraft. It is a 3D Robotic Solo weighing atotal of3.3 lbs. (1.5 kg) 

### I3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal. The dimensions are 10 in. tall (25 em), 18 in. (46 em) motor-to-motor. Understill airthe maximum speed is 50 mph.The 3D Robotics Solo has the ability to hover and move along a vertical and horizontal plane simultaneously. The Solo has four 880 kV motors powered by a Lithium polymer 5200 mAh 14.8Vdc battery. The 3D Robotics Solo controller operates at a frequency of2.4 GHz using a 3DR Link secure WiFi network. The 3D Robotic Solo has a range of .5 miles. Uses Pixhawk2 autopilot. The applicant will operate the UAS in line ofsight. 

## 3D Robotics Solo General Features • Ready to fly • 3-axis camera stabilization • Precision flight and stable hovering • GPS/GLONASS positioning and auto return home • Onscreen real-time flight parameters • High Definition camera • Film straight down • Powered by twin on board 1GHz Linux computers • Unique safety features like pause and "safety net" • Advanced Pixhawk 2 autopilot system • Customizable color LEOs to assist orientationTransmitter • Operating frequency: 2.4 GHz • Communication distance (open area): .5 miles • Battery:2600 mAh 7.2 Vdc rechargeable lithium ion • Voltage: 14.8 VDC

Camera • HD recording: 4k @ 24fps 

### I 1080p @ 60fps • System requirements ofmobile device: iOS 6.0 or above • Mobile Device Support: ipad mini 3 • Max Resolution: 4096 x 2162@24fps Because ofthe small size ofthe UAS and the controlled environment provided the proposed operations will adhere to the Reform Act's safety requirements.The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise,the grant ofthe requested exemption is in the public interest. Accordingly the applicant requests that the FAA grantthe requested exemption with minimum delay. Aircraft and Equivalent Level ofSafety The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft.These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include: • The UAS will weigh less than 55 lbs. 

### (30 Robotics Solo weighs 

### 3.3 lbs.) • The UAS has a maximum speed of50 mph. • Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). • Maximum flight time for each operational flight will be 22 minutes. Flights will be terminated at 25% battery

power reserve or22 minutes offlight time whichever occurs first. • Flights will be operated at an altitude of no more than 400feet above Ground Level (AGL) and not more than

200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist ofthe UAS Pilot and may include the Visual Observer (VO).• A briefing will be performed regarding the planned UAS operations priorto each day'sflight consisting ofall the day's filming or other activities. • All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. • The flights will will occur no closerthan a 5 mile radius ofthe geographic center/Airport Reference Point

(ARP) ofatower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation offlight and other pertinent information. • The operatorwill file FAA Form 7711-1 , or its equivalent,as modified in light ofthe requested exemption,with

the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. • The operatorwill obtain verbal/written consent ofall persons involved with the planned operation to ensure

that only consenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM.With the advanced permission ofthe FSDO, operations at closer range may be approved. • The PIC and VO will be able to communicate by voice, radio, and/ortext at all times. • Written and/orverbal permission and permits will be obtained from territorial,state, county or city

jurisdictions, including law enforcement, fire or other appropriate governmental agencies. • Ifthe UAS loses communication with the remote controller or loses GPS signal, the UAS has the capacity to

return to a pre-determined location within a designated location and land autonomously. • The UAS has the ability to abort a flight in case of unpredicted obstacles, weather, oremergencies.
14CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR 91.203 (a) (1) Subpart H, entitledAirworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR 91 .203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by theApplicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe ReformAct. The Federal AviationAct (49 U.S.C.44701 (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement ofan airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposedwill be at least as safe, or safer,than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. (3.9 lbs.) fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. The FAAwill have advance notice ofall operations. These safety enhancements provide a greaterdegree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threatto national security posed by the UAS,due to it's size, speed of operation, location ofoperation, lack ofexplosive materials orflammable fuels, and inability to carry a substantial external load.14CFR 45.23 (b). Marking oftheAircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also displayon that aircraft neareach entrance tothe cabin,cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Given the size ofthe UAS, two inch lettering will be impossible. 14 CFR 91.7 

### (a): Civil AircraftAirworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equilalent level ofsafety will be provided. 12 CFR 91.9 (b) (2): CivilAircraft Flight Manual in theAircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. -registered civil aircraft ... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by 21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. 14CFR 91.103: PreflightAction. The regulation requires each pilot in command to take certain actions before flight to ensure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. 14CFR 91.109: Flight Instruction. Section 91 .103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design, do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a numberofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety provided by the fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.14 CFR 91.121: Altimeter Settings. The regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure."As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed.An equivalent level ofsafety will be achieved by the operator, pusuantto the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14CFR 91.151 (a): Fuel Requirements for Flight in VFR Conditions. Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed - (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least45 minutes." The battery powering the UAS provides approximately a maximum of22 minutes of powered flight. to meetthe 30 minute reserve requirement in 14 CFR 91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylight ortight VFR conditions is reasonable. The applicant believes that an exemption from 14 CFR 91.151 (a) falls within the scope ofprior exemptions. Operating the UAS, in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility forwhich the exemption will be granted.Applicant believes that an equivalent level ofsafety cab be achieved by limiting flights to 20 minutes or25% ofbattery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14CFR 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The regulation provides in pertinent part: (a) Except as provided in 91 .715, no person may operate a civil aircraft unless it has within it the following (1) An appropriate and current airworthiness certificate ... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the UAS.14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2);417 (a) and (b): Maintenance Inspections. These regulations require that an aircraft operator orowner "shall have that 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 part 43 ofthis chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook.An equivalent level ofsafetywill be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from no higherthan 400 feetAGL. The operatorwill ensure that the UAS is in working order priorto initiating flight, perform required maintenance, and keep along ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain each aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM ,the operatorwill ensurethat the UAS is in working order priorto initiating flight and perform required maintenance needed. Additional Information. The applicant has an in-depth understanding ofthe capabilities and safety concerns involved in using this technology as an asset to the community. Satisfaction ofcriteria provided in Section 333 ofthe ReformAct of 2012 provide more than adequatejustification forthe grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UAS.



# Sin**:v4~~ d**  Johnny Hyman Eye in the Sky Productions 3108 Cypress Mill Rd. Apt. 42 Brunswick, Georgia 31525 904-962-8700