January 15, 2016

Federal Aviation Administration (FAA) U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE West Building, Ground Fl oor, Room W12-140 Washington, DC 20590

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT

Dear Sir or Ma’am:

This petition is being submitted on our behalf with out legal counsel or counseling services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Gifted Studio, LLC., a photographic and gift busine ss (GS), hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft Systems (sUAS) commercially in airspace regulated b y 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

Section 333.

The requested exemption would permit GS to pursue i ts commercial interests in providing aerial data capture to clients using a small advanced sUAV in t he following areas:

- Real Estate - Marketing - Mapping - Surveying - Special Events - Agriculture - Inspection - General Photography

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 – 91.417Gifted Studio, LLC. is co-owned by Theodore L. John son and Melissa S. Johnson. Mr. and Mrs. Johnson

are both involved in the agricultural industry in I owa. Mr. Johnson also holds a Private Pilot certif icate. The company intends to use a DJI Phantom III for ae rial photography. This will serve to improve farm efficiency by allowing visual observation of crop p rogress. Real estate photography and inspection photography will also be more efficient and safer a s using an sUAV avoids the high risks in a helicopt er and/or fixed wing aircraft with fuel and persons on board. The reduced noise and size creates a much smaller environmental impact which promotes public and environmental safety.

To make sure the operation will be safely conducted , TGS will ensure that the PIC for all operations holds a sport, private, or commercial pilot certifi cate, and uses a Visual Observer (VO) at all times . The PIC and VO will survey the flight area for any mobi le phone base stations, radio transmission towers, power lines, or any other electromagnetic interfere nce that could disrupt flight. The PIC and observer will scan the area for any large buildings or trees that may affect with GPS accuracy or flight. Both PIC and Observer will verify the weather is safe for fl ight 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 PRO CEEDURES in a secure area safe from persons and property.

The DJI Phantom 3 Professional is equipped with a b uilt-in stabilized HD camera and GPS safety feature s. These safety features include the ability to restri ct 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 connec tion is restored, the PIC can regain control of flight and land manually.

These specifications meet or exceed the Model Aircr aft 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 FOP M. Such operations will ensure the sUAS will “not crea te a hazard to users of the national airspace syste m or the public.” - When flying the sUAS within three (3) miles of an airport, airport operators will be notified and th e 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 re ach 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 p latform 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 t han 25 pounds, including all payload. - The sUAS will operate at speeds not to exceed 50 knots, can hover and can simultaneously move vertically and horizontally.
- Given the small size of the sUAS and the restrict ed environment within which it will operate, TGC operations will adhere to the reform Act’s safety r equirements.We respectfully request exemption under Section 333 to enable Gifted Studio, LLC to operate efficient,

limited, low-risk commercial sUAS operations for th e activities stated respecting at all times the spa ce and privacy of citizens and property while keeping airspace safe.

Respectfully,

Melissa S. Johnson Gifted Studio, LLC
6421 Wolf Creek Tr. Cedar Rapids, IA 52411