United States Department ofTransportation Docket Management System 1200 New Jersey Ave., SE West Building Ground FloorRoomW12-140 Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act of2012 August 28, 2015 Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and C.F.R. Part 11, Michael Stephenson Owner and operator ofSmall Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FARs) listed below so Michael Stephenson may operate UASs commerciallyin airspace regulated bythe Federal Aviation Administration; as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by section 333. The Name and address ofthe applicant is: Michael Stephenson Entertainment 2018 Archdale Broken Arrow Oklahoma74014 615-498-8683 tvproducermike@gmail.com As described below, the requested exemption would permit the operation oflightweight (less than 55 lbs. total take offgross weight) UASs under controlled conditions for commercial use byprofessional certificatedpilots thereby enhancing safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. Michael Stephenson. respectfully requests the grant ofan exemption to the following specific sections ofthe Title 14 Code offederal Regulations allowing it to operate lightweight UAS's for commercial use: 14 CFR 21, subpart H, 14 CFR45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) &(b) & Closed Set Photography & Video. Michael Stephenson. submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR's operating to prevent future commercial use ofsmall UASs to operate in the national airspace system as described below. The Reform Act Section 332 provides for such integration ofcivilunmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Michael Stephensons lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and therefore the integration ofMichael Stephensons lightweight UASs are expressly contemplatedbythe Reform Act. Michael Stephenson would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAAto promulgate rules governing such aircraft. The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUASs do not create a hazardto users ofthe NAS orthe public orpose a threat to national security in light ofthe following:

• The UAS's size, weight, speed and operational capability • Operation ofthe UAS in close proximityto airports and populated areas • Operation ofthe UAS within visual line ofsight ofthe operator Reform Act 333 (a) Ifthe secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the National Airspace System."

Michael Stephensons UAS's are rotorcraft weighing less than 55 pounds including payload. They operate at a speed ofless than 50knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will operate only within the line ofsight ofthe pilot within a protected flight area as described below. Such operations will insure that the UASs will not create a hazard to the users ofthe national airspace system or the public. The small nature ofthe UASs utilized byMichael Stephenson. combined with the safety protocols outlined below will allow for a greaterthan equivalent level ofsafety in which Congress envisioned that the FAA must, byexemption allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the areas and altitudes they will operate, approval ofthe exemption presents no national security issue and absolutely minimal safetyconcerns which have been mitigated through a rigorous risk management process. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, the significant public benefit, including enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact ofgreatly reducing the cost ofaerial photography therebybenefiting the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.The following limitations are considered tobebinding for the operation ofUASs for commercial purposes byMichael Stephenson: 1. Flights will be operated in the line-of-sightby a ground-basedpilot 2. Flights will only occur in the daytime and clear ofclouds 3. The UASs will weigh less than 55lbs attake offand during flight 4. Flights will be terminated with 25% ofbatterylife remaining 5. Flights will be operated at an altitude at orbelow400' AGL

6. Pilots, camera operators and observers will betrained as to the applicable portion of the UAS's manual as well as the SOPs.

7. Minimum UAS crew willbe one certificated Private/Instrumentrated pilot orhigher rating with a currentFAAmedical. Acamera operator and orobservermaybe added as requiredto further reduce the possibility oftask saturation bythe pilot depending onthe mission requirements.

8. Pilot, observer and camera operatorwill maintain real time communication capability throughout flight operations.

9. The UAS Pilot will conduct a full site surveyto determine the Area ofResponsibility (AOR). This AORis the actual area for UAS operations for a particular day. Each survey will include the assessment ofpotential hazards to includebut not limited to airspace classification, NOTAMS, temporary flight restrictions, closest airport proximity, natural and manmade obstacles, and unnecessary persons which maypose a riskto operations or safety. Ifdeemed necessary, the crew will employ additional personal as safety observers. 10. Michael Stephenson will employ safety observers as well as sign notifications in areas close to public activity.11. Athoroughbriefing will be conducted, prior to the first flight ofthe day in an AOR, utilizing the briefing guide in the SOPs. All persons who will be in the AOR while UAS flights are conducted will be present for this briefing.

12. Michael Stephenson. will obtain consent (verbal or written) for any persons who need to be within 100 feet ofUAS flight operations.

13. Written and or verbal permission from the relevantproperty owners will be obtained prior to flight.

14. All required permissions and permits wouldbe obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire orother governmental agencies. 15. Ifthe UAS loses communications orloses its GPS signal, the UAS will have the capability to return to a pre-determined location within the AOR and land autonomously. 16. The UAS will have the ability to abort a flight in case ofunpredicted obstacles or emergencies. 14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203 (a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR 91.203(a)(l) The size, weight and defined area ofoperations for Michael Stephenson's UAS flights permits exemption from Part 21 because Michael Stephenson. meets an equivalent level ofsafety pursuant to Section 333 ofthe Reform Act. TheFAAis authorized to exempt aircraft from the airworthiness certificate requirement underboththe ACT (49 U.S. C. 44701(f)) and Section 333 ofthe ReformAct. Bothpieces oflegislation permit the FAAto exempt UASs from the airworthiness certificate requirement in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Michael Stephenson meets or exceeds each ofthese elements. 14 C.F.R. 91.203 (a &b) provides for carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons stated above. The equivalent level ofsafety will be achievedbymaintaining such certifications and registrations at Michael Stephensons flight operations center. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplatedbythe FARs, this regulation is inapplicable. 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots ofpassengers, and given the size ofthe UASs, this regulation is inapplicable. An equivalent level ofsafety will be achievedby maintaining an operators manual at the flight operations center. The FAAhas previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738,9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. 91.103(b) Preflight actions 14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include: (b) For any flight, runway lengths at airports ofintended use, and the following takeoffand landing distance information. This subparagraph is not applicable due to our offairfield operations. 14 C.F.R. 91.109 Flight instructions; Simulatedinstrument flight and certain flight tests. 14 C.F.R. 91.109 and all the subparagraphs address the operation ofa civil manned aircraft in conjunction with training and flight tests. The UAS to be employedbyMichael Stephenson are not designated in this category. 14 C.F.R. 91.121 Altimeter Settings 14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Michael Stephenson's UASs utilize GPS systems and internal gyroscopes to provide spatial stability and a reference datum. 14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions 14 C.F.R. 91.151 prohibits an individual from beginning a "flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and assuming normal cruising speed. The battery powering the UAS provides approximately 15 minutes ofpowered flight, which is less than the reserve requirement alone byFARs for day. Given the limitations on the UAS's flight envelope, proposed AOR size, battery life and its ability to land immediatelyit is reasonable to allow an exception. An equivalent level ofsafety can be achievedby limiting flights to 25% ofbattery power. This restriction wouldbe more than adequate to return the UAS to its planned landing zone in the AOR. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 and 10808.14 C.F.R. 45.23 Marking ofthe Aircraft Applicable Codes ofFederalregulations require aircraft to be marked according to certain specifications. Michael Stephensons UASs are unmanned; do not have a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, two-inch lettering is impractical to place on such small aircraft. Michael Stephenson. will, however, place the word "EXPERIMENTAL" on its fuselage as requiredby 14 C.F.R. 45.29 (f) so that the pilot, camera operator, observer and any otherpersons operating in the AOR can see the markings on the UAS. The FAA has previouslyissued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 A, and 10700. 14 C.F.R. 91.119 Minimum Safe Altitudes 14 C.F.R. 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Michael Stephenson will only operate its UASs at orbelow 400 AGL. Michael Stephenson. will operate its UASs in a defined AORthat has been carefullyreviewed for hazards and minimizes the presence ofanypersons not essential for operations. Flights will onlybeconducted over private property with consent ofthe property owner. The equivalent level ofsafetywill be achieved given the size, weight and speed ofthe UAS as well as the location where it is operated. Comparedto flight operations with traditional aircraft or rotorcraft weighing far more than 55lbs, operating below 500 AGL with flammable fuel UAS operations present a far smallerrisk. 14 C.F.R. 91.405 (a), 407 (a)(l), 409(a)(2), 417(a&b) Maintenance Inspections These regulations require that an aircraft operator orowner "shall have the aircraft inspected as prescribed in subpartE ofthis part and shall betweenrequired inspections, except as prescribed inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter, and others shall inspect ormaintain the aircraft in compliance with Part43. These regulations only applyto aircraft with an airworthiness certificate. They will not, therefore, apply to Michael Stephensons UASs should its requested exemptionbe granted. As an equivalent level ofsafety Michael Stephensonrequires its pilots to conduct a preflight, through flight andpostflight inspection ofthe UAS to ensure its flight worthiness prior to launch. Each UAS is flown in compliance with the applicable manufactures manual to include all software update cycles as well as flight checklists. In the event ofa malfunction the UAS can landimmediately.Privacy All flights will occur overprivate or controlled access property with the property owner's prior consent and knowledge.

Summary Michael Stephenson is seeking exemption from the following rules: 14 CFR 21, subpart H, 14 CFR45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a)&(b)·

..and Closed Set Photography and Video. Approval ofthe above exemptions allowing commercial operations ofsmall UASs in the service ofaerial and closed set photography, inspections ofall kinds, real estate surveys, etc. will greatly enhance safetybyreducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft weighing thousands of pounds and carrying hundreds ofpound offuel presenting a significant risk to life and property. With Michael Stephenson's use ofsmall UASs weighing less than 55 lbs., poweredbybatteries and operating at orbelow 400 AGL they virtually eliminate all of the risk associated with traditional aerial & closed set photography. The UASs will carry no people thereby eliminating the exposure to the risks associated with flying while accomplishing the same task in a much safer manner. Granting Michael Stephenson the above exemptions will allow for the expansion ofUAS systems into the future, in a professional, safety conscious culture steeped in the tradition ofAviation. The safety culture establishedbyMichael Stephensonis based on our 20+ years ofbusiness experience. Michael Stephenson respectfully requests that the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought byMichael Stephenson pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Sincerely,

Michael Stephenson 2018 Archdale Broken Arrow Oklahoma74014 tvproducermike@gmail.com 615-498-8683