October 20, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12

- 140 Washington, DC 20590

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Thought Factory LLC, a software and marketing business, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed be low to allow operation of our Small Unmanned Aircraft Systems (sUAS) commercially in airspace regulated by the FAA so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Sec tion 333.

The requested exemption would permit Thought Factory LLC to pursue its commercial interests in providing aerial data capture to clients using a small advanced sUAV in the following areas:

 General Photography

 Real Estate

 Marketing

 Surveying

 Special Events

 Agriculture

 Inspection

Regulations from which exemption is requested:

 14 C.F.R. Part 21

 14 C.F.R. 45.23(b)

 14 C.F.R. 61.113(a) & (b)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9(b) (2)

 14 C.F.R. 91.109

 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a) & (b)

 14 C.F.R. 91.205(b)

 14 C.F.R. 91.215

 14 C.F.R. 91.401

– 91.417I, Robert Fizer , am a sUAV hobbyist. I have been flying sUAVs for over a year. My most recent experience is with a DJI Phantom 3 Professional. I have been flying as a hobbyist and now ready to bring my skills to a professional level. In doing so, I consider all safety precautions and regulations as foremost with each flight.

My request to operate commercially is primarily to record digital video data and o ther aerial photography data for privately owned business which will assist in the promotion and marketing of their own companies or products for sale. For a small budget compan ies and average homeowners

, the expense of such aerial videography is cost proh ibitive.

Daniel Wilder (business partners) will act as Thought Factory LLCs Pilot in Charge (PIC). I will be the
observer. Dan Wilder is also an sUAV hobbyi st with a Private Pilots license. He is intimately familiar with FAA flight rules and regulations , communication protocol with Air Traffic Control, emergency flight procedure’s, and of course weather along a given route which met the minimum established FAA regulations for safety to flight.

To make sure the operation will be safely conducted, the PI C and observer will survey the flight area for any mobile phone base stations, radio transmission towers, power lines, or any other electromagnetic interference that could disrupt flight. The PIC and observer will scan the area for any large buildings or

t rees that may affect with GPS accuracy or flight. Both PIC and Observer will verify the weather is safe for flight to avoid wind speed exceeding 10 m/s, snowfall, rainfall, and restricted environmental visibility . Additionally, the PIC and Observer will go through the PREFILGHT CHECKLIST/maintenance and FLIGHT TEST PROCEEDURES in a secure area safe from persons and property.

The DJI Phantom 3 Professional is equipped with a built

- in stabilized HD camera and GPS safety features. These safety features inclu de the ability to restrict the maximum altitude they operate above ground level (AGL), to limit the radial distance from the operator and to exclude them from operations within designated Class B, C and D airspace including “no

- fly zones”. This model has a failsafe function that is automatically engaged in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safely . If the connection is restored, the PIC ca n regain control of flight and land manually.

These specifications meet or exceed the Model Aircraft Operating Standards as set below:

- The petitioner will only operate its sUAS in line

- of

- sight of a PIC and/or Observer and will operate at sites that are “sufficient distance” from populated areas within the sterile area described in the FOPM. Such operations will ensure the sUAS will “not create a hazard to users of the national airspace system or the public.”

- When flying the sUAS within three (3) miles o f an airport, airport operators will be notified and the operator will give the right

- of

- way to avoid flying in the proximity of full

- scale
aircraft.

- Maximum flight time for each operation will be 30 minutes.

- Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS.

- The sUAS will be pre

- programmed so it will not be operated at an altitude that will exceed 200 feet AGL, and not more than 100 feet above an elevated platform from which videography is planned.

- Minimum crew for each operation shall consist of: sUAS PIC and a visual Observer.- The sUAS operated by the Petitioner weighs less than 25 pounds, including all payload.

- The sUAS will operate a t speeds no t to exceed 50 knots, can hover and can simultaneously move vertically and horizontally.

- Given the small size of the sUAS and the restricted sterile environment within which it will operate, Helena Real Estate solutions, INC operations adhere t o the reform Act’s safety requirements.

We respectfully request exemption under Section 333 to enable Thought Factory LLC to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated respecting at all times the space and p rivacy of citizens and property while keeping airspace safe.

Thank you

,

Robert Fizer Thought Factory LLC

PO Box 291580 Port Orange, FL 32127

386.852.7900