### Videophotog	Productions	(Videophotog.com)

256	Tropic	BLVD	East

Largo,	FL	33770

dan@videophotog.com

727 492 3223	Dan	Foard C ell P hone

cameron@videophotog.com

727 600 5299 Cameron	Foard	Cell	Phone

June	9 ,	2015

US	D epartment	Of	Transportation

Federal	Aviation	Administration

800	Independence	Ave	SW

Washington	DC 20591

Dear Sir or M adam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the

refor m act) and CFR Part 11 Videophotog Productions (Videophotog.com) , owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Videophotog Productions (Videophotog.com) may operate UASs commercially in airspace regulated by the FAA., as long as suc h operations are conducted with in and under the conditions outlined

herein or as maybe established by the FAA as required by Section 333.

Videophotog Productio ns (Videophotog.com) is co

- owned by Daniel Foard and Cameron

Foard . Both are Broadcast Television Sports SPSG Safety certified Camera operators and experienced Drone pilots . Both have Florida Drivers licenses. Daniel Foard has a private pilot’s licens e a nd will be the PIC. All operations will be performed with the public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for

c ommercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for safe operation of such aircraft systems in national airspace systems.” Section 333(c) , o f the Reform Act.Videophotog Productions (Videophotog.com ) UASs are rotorcraft weighing less than 55 pounds including payload. ( The DJI Inspire 1 Quad Copter and t hey operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. Both have an auto return to launch poin t when battery power is under 25 %. The UAS will operate within the line of sight with in a p rotected flight area as described be low and at 2 00 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.

Videophotog Productions (Videophotog.com) respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (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)(1), 91.409(a)&(b).

Videophotog Productions (Videophotog.com) 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 Videophotog Productions (Videophotog.com) future

commercial use of small UASs to operate in the national airspace system as described

below. The reform Act sect ion 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. Videophotog Productions (Videophotog.com) UASs meet the definition of “small

unmanned aircraft” as defined in Sec tion 331 and therefor the Reform Act expressly contemplates the integration of these UASs

. Videophotog Productions (Videophotog.com) would like to operate its light weight UASs 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 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.Videophotog Productions (Videophotog.com) are rotorcraft weigh ing less than 55 lbs. and

the y operate at speeds less than 50 knots and have the capability to operate in the vertical and horizontal plane simultaneously. The UASs will operate only within the lin e of sight of the operator with in a protected flight area a nd at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very small nature of these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Co ngress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and abs olutely 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 of enhanced safety, reduced emissions utilizing UASs verse s traditional aircraft as well a s the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of Videophotog Productions (Videophotog.com)

,

1. Flights will only occur in VFR conditions.

2. Flights will be operated in th e line of sight of the operator ( PIC ) and Observer, (VSO)

3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers recommendations,

4. The UASs will weigh less that 55 lbs.,

5. Flights will be opera ted at 2 00 feet AGL or less.

6. Crew w ill be at a minimum of operator (PIC) and an observer and/or camera
operator (VSO)

, 7. Operator and crew will remain in contact during the flight operation,

8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area,

9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violating anyone’s privacy.

10. All required FAA clearances, will be obtained and distances from airp orts strictly

observed.

11. All UASs will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working.

12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be

assi gned to operate the UASs at a safe distance from the main fishing boat.

13. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining.

14. Flight team will communicate by voice and the use of two

- way r adio if the area is too large to hear voice from all team members.

15. UASs will be used to video private outings and functions

, Automobile racing, boating, jet skiing, kayaking, fishing trips and sporting e vents f rom a safe distance.16. When operating over or ne ar water the UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water

table.

14 CFR part 21 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 Videophotog Productions (Videophotog.com), UASs flights permits

excep tion from Part 21 because they meet 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 USC 4470(f) and Section

333 of the R eform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Videophotog Productions (Videophotog .com), meets or exceeds each of these elements

As of March 23, 2015 the FAA has stated that it will automatically grant a “blanke t” COA

for flights at or under 4 00 AGL to any UASs operator with a section 333 exemption.

14 CFR 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 maintaining such certifications and registrations at Videophotog Produc tions (Videophotog.com), operations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. A s there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of saf ety will be achieved by maintaining such certifications and registrations Videophotog Productions (Videophotog.com), operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,1016 7,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Videophotog Productions (Videophotog.com), w ill onl y operate its UASs at or below 2 00 AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has consented and all persons

with in this video area also give consent for this filming. Compared to flight operations of

conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs.

, operating below 500 AGL with flamm able fuel UASs operations present a far smaller risk to the public.Approval of these 333 Exemption s allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk

associate d with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general.

With the use of sma ll UASs of 55 lbs. or less, battery operated and fl ying below 2 00 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Videophotog Productions (Videophotog.com), will give the people another avenue to express themselves and to

h ave a video record to share with family and friends forever.

Granting Videophotog Productions (Videophotog.com), the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses.

Videophotog Productions (Videophotog.com), Has in the past, and plans in the future to train, promote safe operation and safe flight operations to all pilots of unmanned aircraft in this category private and commercial, and has been involved in assisting several law enforcement agencies and local FAA officials in apprehending safety violators.

Videophotog Productions (Videophotog.com), respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by 

### Videophotog	Productions	(Videophotog.com) pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).



### Sincerely

Daniel	Foard	&	Cameron	Foard

Videophotog	Productions	(Videophotog.com),

256	Tropic	BLVD	East

Largo,	FL	33770