**Fine Mark Media Corey Hannigan**  **723 Nova Court Worthington, Ohio 43085**  **614.595.8503 Sales@FineMarkMedia.com**  December 29, 2015 U. S. Department of Transportation Federal Aviation Administration Docket Management System 800 Independent Ave., S.W

. 1200 New Jersey Avenue Washington, D.C. 20591 SE Washington, DC 20590 FAA Section 333 Application filed via FAA Section 333 Petitions Shell Docket **Re:** Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the FAA Regulations and certain parts of the FARs. Dear Representative of the Federal Aviation Administration: Please be advised that by this letter I am writing as President of F ine Mark Media to request an exemption pursuant to Section 333 of the FAA Modernization Reform Act of 2012 and the procedures contained within 14. C.F.R. §11 to operate an unmanned aircraft system (UAS) to conduct aerial photography and videography of real estate, marketing events, agricultural resources , roofing repairs, weddings, landscape and property photography. Fine Mark Media will operate one or more of the following UAS’: **Yuneec Q500,**  **DJ1 Inspire**  **1.** This exemption request is more fully detailed below.
In order to provide safe and environmentally
-friendly aerial videography and photography for public and business interests , I, Corey Hannigan, President of Fine Mark Media , formally submits this request for exemptions from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R

. 91.417(a) and (b), so that I may operate the Yuneec Q500 and DJ1 Inspire 1 in accordance with the guidelines of the UAS’ operator’s manuals 1 as well as in accordance with current FAA guidelines for UAS flight. These UAS will be equipped with detachable cameras and sensors.

1 The	manuals	of	the	Yuneec	Q50 0	and	DJI	Inspire	1	will	be	submitted	upon	request.The unmanned aircraft systems Fine Mark Media intends to use for personal and

business purposes will be safely operated according to the manufacturer’s guidelines and in compliance with all mandates of the FAA. To illustrate Fine Mark Media’s commitment to safety and to evidence the operation of our UAS’ is in the public’s best interest so the FAA can find good cause to grant our requested exemption, I provide you with the following information concerning the UAS’ we intend to use
- Yuneec Q500 and DJ1 Inspire 1 : 1. Each UAS (listed above) weighs less than four pounds including the battery and camera. 2. Each UAS (listed above) will be operated/flown at an altitud e of no more than 400 feet above ground level (AGL) and not more than 200 feet above an elevated platform from which any planned filming would take place. 3. Each UAS (listed above) is electrically powered by a lithium polymer battery which limits maximum flight time for each operation flight to less than 30 minutes. In accordance with manufacturer’s guidelines each flight will be terminated at 25% battery power reserve or 30 minutes flight times, whichever occurs first. 4. Each UAS (listed above) will have a maximum operating speed of 50 mph, but will be operated at speeds less than 40 mph. 5. All flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). Fine Mark Media intends to use 2 operators on site for every filming endeavor. The pilot will maintain a clear line of sight with the UAS and a visual observer will always be in communication with the PIC at all times. 6. I n addition to the PIC and VO, Fine Mark Media will employ a separate camera operator (CO) for filming when necessary. 7. Prior to every UAS flight, a safety briefing will be conducted by the UAS pilot
- advising all involved in the flight of the laws governing UAS’ (both locally and federally) and of the manufacturer’s instructions and safety guidelines

– concerning the production activities of the day. Additionally
- prior to each flight
- the Pilot in Charge (PIC) will perform a pre-fl ight safety inspection of each UAS intended for flight. 8. Fine Mark Media will log all flight activities and, furthermore, will maintain the logs for inspection of local, state and federal review. 9. Fine Mark Media will only fly UAS” wh en permitted by Visual Flight Rules Meteorological Conditions (VMC)
- or when VMC deems flying appropriate. 10. Fine Mark Media’s UAS’ do not have the capability of carrying combustible fuel, nor are they able to carry crew. As such, in accordance with FAA guidelines, Fine Mark Media will not carry crew or carry combustible fuel on any UAS. 11. No flights conducted by Fine Mark Media will take place closer than a 5 mile radius of an uncontrolled) by an airport. 12. Fine Mark Media commits that it will obtain (documented) verbal or written permission from all persons (including private land owners) within 100 feet of all flight operations

. 13. Each Fine Mark Media PIC, VO and CO will receive training on the operation of all UAS prior to any planned flight.14. Each Fine Mark PIC, VO, and CO

– at all times during operation of UAS

–

will have the ability to verbally communicate by voice or radio with each other. 15. In the event any UAS loses communication via remote controller or in the event the UAS loses its GPS signal, every Fine Mark Media UAS has the ability to return to a pre-determined location and thereafter land autonomously. Furthermore, each PIC operating a flight with a UAS owned Fine Mark Media has the capability of aborting the flight in case of an emergency at wh ich point the Return Home Function of the UAS will automatically function. Every Fine Mark Media UAS has the capability of aborting a flight in the event an unpredicted obstacle is encountered, or in bad weather or in the event of a low battery or other unpredicted emergency. 16. Fine Mark Media agrees to notify th e FAA in the event any incide nt, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA within 24 hours. All accidents will be reported to the National Transportation Safety Board (NTSB) pursuant to the instructions provided on the NTSB website. www.ntsb.gov.
The exemptions proposed will allow me to operate Fine Mark Media’s **Yuneec Q500,**  **DJ1 Inspire**  **1** UAS’ as a service to the public and business interests for the personal and commercial purposes outl ined above

– specifically for performing aerial videography and photography as a service to public and business interests , including: real
-estate photography and videography, wedding and private individual photography and videography, public and commercia l photography and videography, and agricultural photography and videography (including landscapes and properties) and for photography and videography of marketing events

. The FAA recently approved similar use of the UAS owned by Fine Mark Media

. 2 These UASs have been proven reliable and safe flying machines managed by gyroscopically
-stabil ized flight, ground detection , GPS
-aided navigation, a built
-in compass, blinking LED lights , manual and automatic failsafe modes for returning to the controller, and propeller guards in order to protect both the UAS and the environment

. The models I’ve listed combine state
-of
-the
-art, proven technology with high quality manufacturing and user-friendly control to ensure safe operation and easy maintenance

. **Specific se ction or sections of 14 CFR**  **from wh**  **ich I seek relief and the reason I seek relief:**  14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating areas associated with the aircrafts to be utilized by Fine Mark Media, an exemption from Part 21 is appropriate. The UAS’ listed in this application meet the requirements of an equivalent level of safety

2 See	FAA
-2015
-3210,	FAA
-2015
-3329,	FAA
-2015
-4365	and	FAA
-2015
-4414.under Part 11 and Section 333 of the Reform Act. Pursuant with Exemption No.

12045, “i n all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed.” 14 C.F.R. 45.23: Display of marks: general Because our UAS’, the **Yuneec Q500,**  **DJ1 Inspire**  **1,** will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark words, numbers, or phrases, I request exem ption from the above regulation as the regulation appears inapplicable. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command Pursuant to Exemption 12045, “The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138.” 14 C.F.R 91.7: Civil aircraft airworthiness Currently there is no certificate applicable to UAS, and therefore it will be up to me, Corey Hannigan

– President of Fine Mark Media , to determine the airworthiness of the **Yuneec Q500,**  **DJ1 Inspire**  **1** in accordance with the official operating manuals of each unit

. Pre
-/ post
-flight inspections of the propellers, motors, frame, landing stands, camera and gimbal will be performed before and after each flight, accurate records of which will be kept with the UAS’s storage and transportation system at all times. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Please note that pursuant to Exemption 12045, since there are “no pilots or passengers on board this aircraft, and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator.” 14 C.F.R. 91.119(c): Minimum safe altitudes As indicated above, I, Corey Hannigan

– President of Fine Mark Media
- will ensure that any UAS owned and operated by Fine Mark Media does not operate any higher than 400 feet above ground level. I will not fly over congested areas . Iwill plan operations before hand for proper flight safety and proper height analysis

as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings Both the **Yuneec Q500**  and the **DJ1 Inspire**  **1** utilize electronic GPS with barometric sensors with live data output to the mobile device attached to the transmitter. An equivalent level of safety will be achieved by using this function

. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions As indicated above, the UAS that Fine Mark Media will fly are electrically
powered by lithium ion batteries specifically manufactured for each particular UAS

. They are rated at no longer than 30 minutes of flight time. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS’. I, Corey Hannigan

– President of Fine Mark Media , however, will always that I fly safely while having the manuals of the **Yuneec Q500**  and the **DJ1	Inspire	1** available. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records: Maintenance inspections for all Fine Mark Media UAS’ will be performed prior to every flight. Further maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I, Corey Han nigan

– President Fine Mark Media , will perform both preflight and post
-flight inspections of all UAS’ utilized before and after each flight as outlined in the operating documents. I, Corey Hannigan

– President of Fine Mark Media , will also follow manufacturer recommendations from said operating documents. **Public Interest:** Aerial photography and videography provided to the public allows for a more cost
-effective and environmentally
-friendly method of capturing imagery than its alternative: manned aircraft and helicopters. Manned aircraft and helicopters are expensive to operate. They create excessive noise and environmental pollution , and are much more hazardous to the public due to their size and because they necessarily carry combustible fuel. Without question, UAS’ are far safer thanmanned flying machines

– both in terms of safety for citizens and safety for the environment. I n addition to using my UAS’ for commercial endeavors, Fine Mark Media will also offer its services
- upon request
- to benefit the public. Wh ile Fine Mark Media has no intention of soliciting gratuitous opportunities to serve the public, Fine Mark Media’s commits it’s services to the public upon request. G iven that there is no fuel and no crew on the UAS’ owned by Fine Mark Media , and considering that the Yuneec Q500 and the DJ1 Inspire 1 weigh u nder four pounds, has propeller guards
- as well as having a low maximum speed (less than 25mph)
- the safe operation of Fine Mark Media’s UAS’ will not pose any immediate danger to the environment, wildlife, or individuals. Also, please consider the units described above possess GPS and ground
-sensing capabilities, along with safety features designated as a “return” mode that will safely return the crafts to the PIC at the push of a button or – importantly
- automatically when the UAS is low on battery power or if the UAS encounters an unforeseen obstacle. These safety measures ensure all Fine Mark Media UAS’ will not remain airborne in unsafe conditions. The addition of UAS
-controlled aerial video and photography services provides both public and commercial sectors with an environmentally
-friendly and cost
effective means by which to obtain photography and videography services. Because of this, an increase of commercial activity and a gaining of more detailed understanding of private and/or farm land would help local and area communities by: reducing pollution, risk, and operating costs by alternative aerial video and photography services such as manned airplanes and helicopters, reducing carbon emissions and traffic congestion by vehicles looking to view properties such as real
-estate or farm land, and increase visibility to local attractions thereby bolstering local commerce and tourism. **Summary** I seek (on behalf of Fine Mark Media) an exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b)

. With the exemptions of the aforementioned rules, Fine Mark Media will seek to make its photography/videography se rvices available to pub lic and commercial interests. Public and commercial interests have previously sought the use of manned aircraft to achieve what Fine Mark Media can offer

. The difference is Fine Mark Media can offer the above referenced services in a safer, more cost
-efficient and environmentally
-friendly manner to public and private interests by not using combustible fuel, flying at safer heights and by strictly following the usagerecommendations from the operating manuals of the UAS and by complying with

federal, state and local laws

. These safety measures include but are not limited to: ● Flying the UAS’ safely in accordance with each’s operating manual

. ● Always flying below 400 feet

. ● By thorough ly i nspecting each UAS before and after flights and keeping inspection records with the craft at all times

. ● By keeping each UAS in visual sight at all times when in operation

. ● By using an observer to assist the PIC on every flight. ● By remain safely clear of and do not interfere with manned aircraft operations

. ● By not intentionally flying near dangerously or over unprotected persons or moving vehicles

. ● By contact an airport or control tower before flying within 5 miles of their vicinity. The defined policies of Fine Mark Media will never permit flying within 5 miles of an airport or control tower. ● By not flying in adverse weather conditions such as high winds , rain, or impa i red visibility as outlined above. ● By never allowing a PIC to fly under the influence of alcohol or drugs . By mandating that at least 2 people will be present for every flight, Fine Mark Media is able to ensure the enforcement of this statement. ● By unfailing ensuring the operating environment for the UAS is completely safe

. ● By ensuring every PIC will not fly over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc. ● By checking, complying with and following all local , state and federal laws and ordinances before flying over private property

. ● By forbidding all Fine Mark employees from conducting surveil lance or photography of persons in areas where there is an expectation of privacy without an individual's permission

. I have carefully reviewed the criteria set forth for meeting the requirements of my application for an exemption. I hope I’ve accurately met the standards set forth. In the event I’ve omitted necessary information, it’s my hope you’ll contact me in so I can provide any information necessary for the granting of this application.

I sincerely appreciate your consideration of this application and look forward to your timely response.Respectfully submitted, I am

Sincerely, Corey Hannigan President, Fine Mark Media