August 14, 2015 U.S. DepartmentofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590
Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) &(b).
Dear Sir orMadam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act, I, William Driver, operator ofan Unmanned Aircraft System (UAS), hereby apply, on behalfofRadio Star Video, for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.
Iwould like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) ofTitle 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow the operation ofunmanned aircraft systems (UAS) for the purpose ofaerial videography and photography. Applicant: William Driver Owner Radio StarVideo 9311 NFM 620, Ste. 12 Austin, TX 78726 info@radiostarvideo.com (310) 497-6051 Commercial operation ofan UAS, as described herein, which are equipped with camera and sensors, would operate in the following manner: • Aerial photography andjorvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. • Aerial video and/or photography for public andjor private use including television, public events, cinematography and newsgathering. • Aerial inspection/photography ofresidential/commercial structures under contractwith the owners orlocal government authority.• Aerial inspection/photography ofresidentialjcommercial utility infrastructure including but notlimited to electrical power lines, wind turbines and cell towers. • Aerial video/photography or providing live video feed to assistwith search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or governmenthas requested it by contract or donation. • Training to persons individually orbelonging to both private and/or public organizations to increase awareness and improve safetyfor currentand future UAS operations within the NAS. As described fully below, the requested exemption would permitthe operation ofa UAS under controlled conditions in the NAS thatwould be a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements to the already safe operations in the industrypresently using conventional aircraft. Approval ofthis exemption would therebyenhance safety and fulfill the Secretary ofTransportation responsibilities to "

... establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."
We will operate a UAS, the DJI Phantom 3 Professional, which is comprised ofan unmanned aircraft (UA or Phantom), an attached 4K camera and a transportable ground station. The PHANTOM 3 is a quad-copter with a gross weight of2.8 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 16

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We will also operate a UAS, the DJI Inspire 1, which is comprised ofan unmanned aircraft (UA or Inspire 1), an attached 4K camera and a transportable ground station. The INSPIRE 1 is a quad-copter with a gross weight of6.5 pounds. Itis equipped with four rotors that are driven by electric motors powered bybatteries. The UA has a maximum airspeed of22 

### mjs. Both UAS will be operated overvarious metropolitan areas, primarily around Austin, TX. and surrounding areas. UAS Operating Parameters We will abide by the following additional operating conditions underthis exemption, which ensures a level ofsafety atleast equal to existing rules: • The UAS will weigh less than 55 lbs. • Operate UAS below 400 feet and within a radius distance of 1000 feet from the controllerto aid in direct line ofsight visual observation; • Obtain permission from the owner /controller ofanyvessels, vehicles and structures when operations may be conducted closer than 500 feet to anysuch vessels, vehicles or structures; wewill conducta safety assessment of the risk ofoperating closerto those objects and determinethatitdoes not presentan undue hazard; • Operate the UAS for 5-10 minutes perflight; • Land UAS priorto the manufacturer's recommended minimum level of batterypower; • Operate UAS during daylighthours only within visual line ofsight (VLOS); • Use the UAS' global positioning system (GPS) flight safety feature whereby ithovers and then slowlylands ifcommunication with the remote control pilot is lost; • Conduct all operations underthe flight safety protocols (including posting a warning sign reading: "AttentionAerial Photographyin Progress

- Remain Back 150 feet") contained in the operating documents and will actively analyze flight data and other sources ofinformation to constantlyupdate and enhance safety protocols; • Contact respective airports ifoperations will bewithin 5 miles to advise them ofhis estimated flight time, flight duration, elevation offlight and other pertinentinformation; • Always obtain all necessary permissions priorto operation; have procedures in place to abortflights in the eventofsafetybreaches or potential danger; • Only operate in safe environments thatare strictly controlled, are away from powerlines, elevated lights, airports and densely populated areas (defined byareas depicted in "yellow" on VFR charts andthrough obtaining information regarding congested areas from thelocal Flight Standards District Office (FSDO); • Conduct extensive preflight inspections and protocols, duringwhich safety carries primary importance (reference PHANTOM Flying Flow Chart and User Manual). Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics ofthe UAS' performance under different temperature an weather conditions. Any PIC operating our UAS will have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraftpilot including atleast 10hours logged as a UAS pilotwith a multi-rotor UAS. The PIC will also have accumulated and logged a minimum of5 hours as a UAS pilotoperating the same make and model ofUAS to be used for operations. In addition to the hour requirements, the PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currencypurposes) priorto any flight. Specific Exemptions Requested Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption from 14 CFR part

### 21, Subpart H (Airworthiness Certificates) and§91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalentlevel of safety under 14 CFR part 11 and Section 333 ofP.L. 112-95 (Section 333). We requestan exemption from§ 45.23 Marking ofthe aircraft because the UA will nothave a cabin, cockpit or pilot station on which to markcertain words or phrases. Further, the two-inch letteringis difficult to place on such a small aircraftwith dimensions smaller than the minimal lettering requirement. Regardless ofthis, we can markthe UAS in the largestpossible lettering by placing the word "Experimental" on its fuselage as required by§ 45.29(f) so thatanyone will see the markings.
We request an exemption from§ 91.7(a) which prohibits the operation ofan aircraft without an airworthiness certificate, since there is currentlyno certificate applicable to our operation, this regulation is inapplicable. We request an exemption from§§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an Airworthiness certificate. However, as a safety precaution we will perform a preflight inspection ofthe UAS before each flight as outlined in the attached operating documents.
We request an exemption from§ 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety /flight manual with the UAS ground station. We request an exemption from§ 91.119 which prescribes safe altitudes for the operation ofcivil aircraft, butit allows helicopters to be operated atlower altitudes in certain conditions. We will not operate our UAS above the altitude of400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "providing a level ofsafety atleast equivalentto orbelow those in relation to minimum safe altitudes." Given the size, weight, maneuverability, and speed ofthe UAS, an equivalent or higher level ofsafetywill be achieved. We request an exemption from§ 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. We request an exemption from§ 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued- perthe operating documents, the UAV will be landed atthe first alert. Also, our flights will last only 5-10 minutes each, and the UAS has an automated function, which results in immediate landing when a low batteryis detected. The PIC will notbegin a flight unless (considering wind and forecast weather conditions) there is enough power to' 

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fly to the first point ofintended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining. 

### Public Interest Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business success. The industryis not new. However, until recently itwas conducted through the use ofcostlymanned aircraft, a prohibitive business activity for small companies. By granting this exemption Iwould be able to provide affordable services. Further, the small UAS will pose no threatto the public given its small size and lack ofcombustible fuel when compared to larger manned aircraft. Additionally, the operation ofour UAS will minimize harm to the environment economic growth by providing information to companies and the public looking to relocate orbuild in the metro areas we service. Public and private events serviced by ourbusiness enhance vibrancy and add culture to the communityand its citizens. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption and are prepared to modify or amend any part ofthis requestto satisfy the need for an equivalent level ofsafety. We look forward to working with your office. Please contactus at any time ifadditional information or clarifications are needed.

· m Driver Owner/Radio StarVideo 9311 NFM 620, Ste. 12 Austin, TX 78726 310-497-6051 info@radiostarvideo.com