' ........ Docket Operations, M-30 U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. Room W12-140, West Building Ground FloorWashington, DC 20590-0001

DearSirorMadam:

Pursuant to Section 333 of the FAA Modernization and Reform Act Of 2012 and CFR Part 11, DAVIDE CALDA, Videomaker and photographer, owner and operator ofSmall Unmanned Aircraft Systems (UAS's), request to be exempted from the Federal Aviation Regulations (FAR's) listed below so may operate UAS's commercially within airspace regulated by the FAA, as long as such operations are conducted within and under the conditions outlined here in or as may be established by the FAAas required by Section 333. As described below, the requested exemption would permitthe operation of lightweight (less than 55 lbs. total take off weight) UAS's under controlled conditions for commercial use by myself thereby enhancing safety and fulfilling the Secretary ofTransportation's responsibility to "establish requirements for safe operation of such aircraft systems in national airspace systems." Section 333(c), ofthe Reform Act. Davide Calda's Drone is rotorcraftweighing less than 55 pounds including payload (DJI Phantom 3 Quad Copter). They operate ata speed less than 50 knots and havethe capabilityto hoverand move in the vertical and horizontal plane simultaneously. The DJI Phantom 3 has an auto return to the departure pointwhen exceeding the manufacturers recommended distance from the controller, when the signal between the controller is lost or when battery power is under 25%. The UAS will be operated within "line of sight" in a protected flight area at 200' AGL or less. These operations will notcreate a hazard to users ofthe nations airspace orthe public. Davide Calda submits this application in accordance with the Reform Act, 112 P.L. 95 331:334, seeking relief from any currently applicable FAR's operating to prevent commercial use of small UAS'sto operate in the national airspace system as described below. The ReformAct Section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public's interest to do so. I meet the definition of "small unmanned aircraft" as defined by Section 331 and therefor the integration of theses UAS's are expressly contemplated by the Reform Act. I would like to operate it's light weight UAS's prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 ofthe Reform Act. In making this determination, the Secretary ofTransportation is required to determinewhich UAS's do create a hazard to users ofthe national airspace system orthe public or pose a threat to national security in light of the following. The UAS's size, speed, weight and operational capability.

• Operation ofthe UAS's in close proximityto airports and populated areas. • Operation ofthe UAS'swithin visual line ofsightofthe operator. Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in the National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.Davide Calda will be using rotorcraftweighing lessthan 55 lbs and operate at speeds lessthan 50 knots with the ability to operate in the vertical and horizontal plane simultaneously. The UAS'swill operate only within "line ofsight" ofthe operatorwithin a protected flight area and at 200' AGL or less. Thiswill not presenta hazard to the national airspaceorthe public. The very small nature ofthese UAS's combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UAS'sto commence immediately. Also dueto the size of UAS's and the areas and altitudes they will operate approval of this exemption presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level ofenhanced safety, reduced emissions utilizing UAS'sversustraditional aircraft as well as the economic impact ofgreatly reducing the cost ofaerial photography thereby benefitting the greater public's interest. Accordingly, the applicant requests that the FAA grantthe requested exemption withoutdelay. The following will be considered as the Standard Operating Procedures (SOP) : 1.Fiightswill only occur between sunrise and sunset. 2.Fiightswill be operated in the line ofsight ofthe operator (PIC). 3.Fiights will be terminated at any time weatherand wind deteriorateto "unsafeforflight" based on manufacturer's limitations. 4.The UAS'swill weigh lessthan 551bs. 5.Fiightswill be operated at lessthan 200' AGL. 6.The UAS's operatorwill perform a check ofthe flight area and make certain ofthe safety of all persons in the area. ?.Consentwill be obtainedfrom all personswithinthevideo capabilitiesto ensuretheir privacy. 8.AII required FAA clearanceswill be obtained and distancesfrom airportsstrictly adheredtoo. 9.AII UAS'swill have the capabilityto return automaticallyto the operator in a safe mannerwith the auto return function checked and working. 1O.Fiightswill only operate in VFR conditions. 11.UAS controllers display range and remaining battery power. 12.AII preflight checkswill be done priorto each flight. 13.AII routine inspections and maintenancewill be done in accordance as specified by DJI. 14 CFR, Part21 Subpart H: Airworthiness Certificate 14 CFR 91.7 (a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Drone View Aerial Photo UAS's flights permits exemption from Part 21 because they meet an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Davide Calda meets orexceedseach ofthese items. As of March 23, 2015the FAA has stated that itwill automatically granta "blanket" COAforflights at or under200'AGLto any UAS operatorswith a Section 333 Exemption. 14 CFR, Part 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintainingsuch certifications and registrations by DroneViewAerial Photo. 14 CFR, Part 91.7 (a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FAR's this regulation is inapplicable. 14 CFR, Part 91.9(b)(2) requires an "Civil Aircraft Flight Manual" in aircraft. As there are no pilots orpassengers and given the size ofthe UAS'sthis regulation is inapplicable. The FAA has previously issued exemptions to this regulation in Exemptions 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700and 332827. 14 CFR, Part 91.119 Minimum safe altitudes prescribes safe altitudes for operation of civil aircraft

.. It allows helicopters to be operated at lower altitudes under certain conditions. Davide Calda will only operate it's UAS's at or below 200' AGL. They will be operated in a well defined area ofoperation that has been carefully reviewed for hazards and minimizes the presence ofany persons not essential for these operations. Flights will only be over private property with the owner's consent. Approval ofthese 333 Exemptions allowing commercial use ofsmall UAS's in the service ofaerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with fuel potentially flying over or in close proximity to populated areas. With the use ofsmall battery powered UAS's of55 lbs or less the risk ofinjuryto people on the ground is drastically reduced. Granting Davide Calda the above exemption will allow for the expansion of the use of UAS's aircraft in the futureforthe safe conduct offree enterprise. Davide Calda respectfully requests the FAA grant it's exemption without delay. The FAA has the authority to issue this exemption pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the act). Sincerely,

DAVIDE CALDAVIDEOMAKER & PHOTO 2725 South Lockwood Ridge Rd Sarasota 34239 FL Phone (941) 284 2428 Davide.calda@gmail.com