May 18, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from

14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b);

91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2);

91.417(a)&(b)

Dear Sir or Madam,

We, Conn, Inc, dba Stage 2 Studios (hereafter referred to as Stage 2 Studios), are writing pursuant

to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11,

to request that Stage 2 Studios, an owner and operator of small unmanned aircraft, be exempted

from the Federal Aviation Regulations (“FARs”) listed below so that We, Stage 2 Studios, may operate

our small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by

the Federal Aviation Administration (“FAA”).

As described herein Stage 2 Studios are experienced in flying quadcopters for recreational purposes.

Our Inventory includes multiple DJI Inspire 1 and DJI Phantom 2 and Phantom 3 aerial quadcopters

with the intent for aerial videography/cinematography to enhance academic community awareness for

those individuals and companies unfamiliar with the geographical layout of the regions of Alaska,

Colorado and Washington area, and augment nonprofit and community benefit and nonprofit

organizations such as United Way, Jewish Family Service and many others; following exemption and

approval by the FAA.

Having flown small quadcopters over the last 2 years without incident. Committed to safety with each

flight. Stage 2 Studios exemption request would permit operation of ultra light weight, unmanned

(piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited

airspace. Predetermined in areas away from general public, airports, heliports and vehicular traffic

for community videos, and within property boundaries for individual organizations and companies.

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur

hobbyists with no safety plan or controls in place to prevent catastrophe. We, Stage 2 Studios, have

developed and inacted Standard Operating Procedures to avoid and prevent public hazard, as well as

manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight

UAS's specific to real estate video and photography usage as We, Stage 2 Studios, record flight data

and other information gained through permitted flight operations to share with the FAA through any

required FAA reports to assist with future protocol and safety regulation.

Granting our, Stage 2 Studios’s, request comports with the Secretary of Transportation’s (FAA

Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in

the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for

videography / aerial cinematography purposes. Further We, Stage 2 Studios, will conduct our

operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, We, Stage 2 Studios, respectfully request the grant of an exemption

allowing us to operate ultra light weight, remote controlled UAS’s for academic community awareness

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to benefit community impact and nonprofit organizations who cannot afford expensive manned

aircraft for the same purpose. Both of which will promote local economic growth through increased

employment and increased tax base. Both with public safety in mind by keeping heavier manned

aircraft containing combustible fuel that poses potential public hazard.

I. Contact Information:

Stage 2 Studios, DBA Conn, Inc

President / Owner: John Conn

5610 S. Ouray St; Centennial, CO 80015 Phone: 720.215.5087

Email: john@stage2studios.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Stage 2 Studios,

DBA Conn, Inc. Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Stage 2 Studios seeks and the Reason He Seeks Such Relief:

We, Stage 2 Studios submit this application in accordance with the Reform Act, 112 P.L. 95 §§

331-334, seeking relief from any currently applicable FARs operating to prevent we, Stage 2 Stdios.

contemplated commercial cinematic, academic and other flight operations within the national airspace

system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft

systems into our national airspace system as it is in the public’s interest to do so. Our, Stage 2

Studios’s, ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in

Section 331 and therefore the integration of our ultra light weight UAS is expressly contemplated by

the Reform Act. We would like to operate our light weight UAS prior to the time period by which the

Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct

experience and valuable information for formal regulation that can be administered uniformly to all

promotional related UAS aerial video and photography. The Reform Act guides the Secretary in

determining the types of UAS's that may operate safely in our national airspace system.

Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the

UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated

by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for

us,Stage 2 Studios. Our UAS utilizes four (4) counter-rotating propellers for balance, control and

stability. Our UAS is equipped with GPS and auto return safety technology. Weighing less than fifteen

(15) pounds (far below the max. 55 pound limit); including camera with gimbal.

Stage 2 Studios, considers safety as foremost with each flight. Our small unmanned aircraft is

designed to hover in place via GPS and operate in less than a 13 knot (15 mph) wind. For safety,

stability and fear of financial loss we will not fly in winds exceeding 13 knot (15 mph). Built in safety

systems include a GPS mode that allows our UAS to hover in place when radio controls are released.

With three modes to choose from, We utilize the Safe Mode for aerial videography/photography. This

is the safest, most reliable and stable mode to prevent accident and hazard. When pilot

communication is lost UAS is designed to slowly descend to point of take off. No UAS operations near

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airports, Hospitals nor Police heliports, and do not operate near areas where general public is within

fifty to one hundred (50-100) yards depending on location, conditions and weather. We are constantly

on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort

immediately to the nearest and safest ground point should a manned aircraft approach our location or

we suspect manned aircraft may approach near our location. Our UAS is capable of vertical and

horizontal operations, and are flown only within our line of sight of us, as the remote control pilot.

Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to fifteen

(15) minutes, with an altitude under three hundred (300) feet. We, Stage 2 Studios, utilize a fresh

fully charged battery with each flight as a safety precaution; full flight time limit for each battery is

ten (10) to fifteen (15) minutes as tested. We do not operate our UAS at or below manufacture

recommend minimum charge levels for operation; preferring to remain well within a safe operating

range to insure adequate communication between radio control and UAS to eliminate potential for

crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure

replacement for sufficient safe level of operation. We do not believe in taking risk that may cause a

crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an

investment. We have clocked numerous practice flights in remote areas as a hobbyist simulating

flights for future commercial use to gain familiarization with the characteristics of this specific UAS's

performance under different temperature and weather conditions. We have also developed a traing

course manual and outline for new members as well as current. All for the sake of safety.

We, Stage 2 Studios, are extremely cautious when operating our UAS/ultra light weight unmanned

aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L.

95 § 333 (b). Given the small size and weight of our UAS it falls well within Congress’s contemplated

safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's

into the national airspace system. Stage 2 Studios, used in hobby flight, has a demonstrable safety

record and does not pose any threat to the general public or national security.

IV. How Stage 2 Studio’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for storytelling for nonprofit, community impact

organizations as well as to promote natural beauty and tourism for the State of Alaska has been

around for a long time through manned fixed wing aircraft and helicopters. For small budget

companies and average nonprofit organizations the expense of such aerial videography is cost

prohibitive. Only large companies and high end cinematographers can afford to absorb such expense.

Depriving these organizations from a valuable marketing tool. Manned aircraft pose a threat to the

public through potential catastrophic crash that the all of our office location’s communities have

experienced in the past. Each resulting in loss of life. Each with combustible fuel that exploded and

burned on impact. Our, Stage 2 Studios, UAS pose no such threat since size and lack of combustible

fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown

UAS's into the national airspace system, hence the passing of the Reform Act. Granting Our, Stage 2

Studio's, exemption request furthers the public interest through academic/visual awareness of the

natural beauty and community benefits in and around the three states our company operates in. Our

ultra light weight UAS is battery powered and creates no emissions that can harm the environment.

The consequence of our ultra light weight UAS crashing is far less than a full size helicopter or fixed

wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to

the public.

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The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial

video/photo capture through our battery operated ultra light weight UAS's. Permitting us, Stage 2

Studios, to immediately fly within national air space furthers economic growth. Granting our

exemption request substantially furthers the economic impact for the Colorado, Washington and

Alaska communities for companies looking to relocate or build in the areas as well as individuals

looking to relocate for career advancement through academic and geographical awareness. Both of

which serve as a stimulus to the community.

V. Reasons Why Stage 2 Studio's Exemption Will Not Adversely Affect Safety Or How The Exemption

Will Provide a Level of Safety At Least Equal To Existing Rule:

Our, Stage 2 Studios, exemption will not adversely affect safety. Quite the contrary, for the reasons

stated permitting us, Stage 2 Studios, to log more flight time in FAA controlled airspace, with

communication with the FAA, will allow us to contribute to the innovation and implementation of new

and novel, as of yet undiscovered safety protocols for Companies hoping to develop aerial

cinematography for development in cooperation with the FAA. In addition We, Stage 2 Studios,

submit the following representations of enhancements to current aerial videography and photography

for nonprofit and other organizations:

Our UAS weighs less than 15 pounds complete with gimbal and high resolution 4k Cinema Camera

We only operate our UAS below 300 feet (well within the 400 foot permissible ceiling set by the FAA

Modernization and Reform Act of 2012);

Most of our flights would be less than 100 feet above ground level;

Our UAS only operate for 10-15 minutes per flight;

We land our UAS prior to manufacturer recommended minimum level of battery power;

We pilot our UAS through remote control only by line of sight;

Our UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication

with the remote control pilot is lost;

We actively analyze flight data and other sources of information to constantly update and enhance

safety protocols;

We only operate in reasonably safe environment that are strictly controlled, are away from power

lines, elevated lights, airports and actively populated areas;

We conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance;

We always obtain all necessary permissions prior to operation; and,

We have procedures in place to abort flights in the event of safety breaches or potential danger.

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Our, Stage 2 Studio's, safety protocols provide a level of safety equal to or exceeding existing rules.

It is important to note that absent the integration of commercial UAS into our national airspace

system, helicopters are the primary means of aerial video and photography for community awareness

and video production. While the safety record of such helicopters is remarkably astounding, there has

been local incident involving loss of life as well as extensive property damage; it is far safer to

operate a battery powered ultra light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and we only

operate our UAS in specific areas away from mass populations. Second, there is no fuel on board a

UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and

extreme maneuverability of our UAS allows us to remotely pilot away from and avoid hazards quickly

and safely. Lastly, given its small size and weight, even when close enough to capture amazing

images, our UAS need not be so close to the objects they are focused on through the technology and

use of post editing software allowing pan and zoom.

Accordingly, our UAS has been experimentally operated for familiarization/competency and will

continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement

of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of our, Stage 2 Studios’, UAS permits exemption from Part 21 because our

UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act.

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both

the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the

weight, size, speed, maneuverability and proximity to areas such as airports and dense populations.

Our, Stage 2 Studios’s, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no

such certificate will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent

level of safety will be achieved by maintaining a safety/flight manual delineating areas of where

safety can be defined.10 The FAA has 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. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic

global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The equivalent level of

safety will be achieved by maintaining any such re

quired certifications and registrations by us, Stage 2 Studios.

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14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain

specifications. Our UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or

pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place

on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, We will

mark our UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as

required by 14 C.F.R. §45.29 (f) so that we the pilot, or anyone assisting me as a spotter with the

UAV will see the markings. The FAA has previously issued exemptions to this regulation through

Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.133: Commercial Pilot Privileges and Limitations: PIC.

Pursuant to14 C.F.R. § 61.133 (a - i, ii), Commercial pilots are not limited to commercial operations.

We, Stage 2 Studios, can achieve an equivalent level of safety as achieved by current Regulations

because our UAS does not carry any pilots or passengers. The risks attended to the operation of our

UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et

seq. Thus, allowing us, Stage 2 Studios, to operate our UAS and meet or exceed current safety levels

in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to

be operated at lower altitudes in certain conditions. Our UAS will never operate at an altitude greater

than 300 AGL; safely below the standard of 400 AGL. We, Stage 2 Studiosl, will however operate our

UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or

below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed

of our UAS, an equivalent or higher level of safety will be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have

[the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections,

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part

43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore,

apply to our, Stage 2 Studios's,UAS. However, as a safety precaution we inspect our UAS before and

after each flight as well as maintaining a maintanance log.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91:

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness

Certificates, sets forth requirements for procurement of necessary airworthiness certificates in

relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of our UAS permits

exemption from Part 21 because our, Stage 2 Studio’s, UAS meets an equivalent level of safety

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to

areas such as airports and dense populations. Our UAS meets or exceeds each of the elements. 14

C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of

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safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance

program that involves regular software updates and curative measures for any damaged hardware.

Therefore, an equivalent level of safety will be achieved.

In summary, Stage 2 Studios seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 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. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. §

91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a)

& (b) to commercially operate our, Stage 2 Studios, small unmanned vehicle/lightweight unmanned

aircraft vehicle in community awareness and real estate operations, and to develop economic

platforms for real estate to enhance the experience of those seeking to relocate to the Colorado,

Washington or Alaska areas. Currently, area awareness and real estate aerial

videography/photography relies primarily on the use of larger aircraft running on combustible fuel.

Posing potential risk to the public. Granting our, Stage 2 Studio’s, request for exemption will reduce

current risk levels and thereby enhance safety. Our UAS craft do not contain potentially explosive

fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic

aircraft with less flight time. Further, We operate at lower altitudes and in controlled airspace

eliminating potential public risk flying to and from established air fields. We, Stage 2 Studios have

been informally analyzing flight information and will compile safety protocols and the implementation

of a flight operations manual for real estate usage that exceeds currently accepted means and

methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's

internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of

2012. There are no personnel on board our, Stage 2 Studios’, UAS and therefore the likelihood of

death or serious bodily injury is significantly diminished. our, Stage 2 Studio’s, operation of our UAS,

weighing less than 15 pounds and travelling at lower speeds within limited areas will provide an

equivalent level of safety as that achieved under current FARs. Accordingly We, Stage 2 Studios,

respectfully request that the FAA grant our exemption request and are willing to cooperate in sharing

information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Stage 2 Studios John Conn, President

5610 S. Ouray St; Centennial, CO 80015

720.215.5087 john@stage2studios.com

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