Brandon Pierce

Nice People, LLC dba Twiceineveryspeed Photography

1053 Bennington Dr

Charleston, SC 29492

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 and Part 11 of the Federal Aviation

Regulations from 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F. R.

91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409

(a) (2) 14 CFR 417 (a) & (b)

To Whom It May Concern,

I am submitting this exemption request on my own behalf as the managing member of Nice

People, LLC dba Twiceineveryspeed Photography.

Specific Sections in which Nice People, LLC dba Twiceineveryspeed Photography is seeking an

exemption: IN THE MATTER OF THE PETITION FOR EXEMPTION OF: NICE PEOPLE, LLC

dba TWICEINEVERYSPEED PHOTOGRAPHY FOR AN EXEMPTION SEEKING RELIEF

FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F. R. 91.119 14

C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14

CFR 417 (a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)

Extent of relief and our reason for seeking relief:​

In order to use the Unmanned Aircraft Systems listed above for commercial use. This exemption

is being sought to ensure NICE PEOPLE, LLC dba TWICEINEVERYSPEED PHOTOGRAPHY

is able to legally conduct commercial business while complying with all Federal regulations and

standards put forth by the FAA, during operation of the Unmanned Aircraft System.

How our request would benefit the public as a whole:

Granting the petition for NICE PEOPLE, LLC dba TWICEINEVERYSPEED PHOTOGRAPHY

would allow for the ability to efficiently, legally, economically, and safely perform aerial video

and photography in the industries of motion picture and television, commercial photography and

advertising, real estate, short range inspection, mapping and survey over certain areas of these

United States. Using Unmanned Aircraft Systems such as drone technology is preferable over
other forms of aerial photography/cinematography in that it has minimal environmental impact.

There is a decrease in safety concerns with low altitude UAS photography/cinematography over

other forms of aerial photography/cinematography due to a significantly smaller form factor and

use of electric battery power rather than fossil fuels. There is also minimal public disturbance

caused when using UAS photography/cinematography at low altitude in comparison to more

traditional means of aerial photography/cinematography.

Reasons why the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to the existing rule:

By strictly adhering to guidelines set forth by the FAA NICE PEOPLE, LLC dba

TWICEINEVERYSPEED PHOTOGRAPHY would not be going above the recommended altitude

nor flying at night therefore avoiding any hazardous accidents. The UAS will be operated only

within line of site of the PIC or the assigned spotter and never controlled from a moving vehicle.

The PIC will have mandatory hands on training with 20 training hours in non commercial use. All

observers maintaining VLOS during commercial flights will be required to undergo a training

course and have a minimum of 5 hours of observing on non­commercial flights.

NICE PEOPLE, LLC dba TWICEINEVERYSPEED PHOTOGRAPHY will give notification to the

FAA 72 hours prior to any commercial use flights once exemption is awarded but before a COA

is filed. Once exemption is awarded, NICE PEOPLE, LLC dba TWICEINEVERYSPEED

PHOTOGRAPHY will file for a Certificate of Waiver or Authorization FAA Air Traffic Organization

prior to conducting operation in the NAS.

NICE PEOPLE, LLC dba TWICEINEVERYSPEED PHOTOGRAPHY will regularly test the UAS

flight and complete daily maintenance logs proceeding planned flights to ensure the UAS is in

proper working order for each planned flight to prevent damage or bodily injury. A mandatory

preflight check will be completed immediately prior to a commercial flight. The weight of the UAS

is also significantly under the 55 pound maximum, weighing under 5 pounds with camera and

battery on board. The PIC will always fly at the lowest altitude needed, and never to exceed

400ft from the ground.

Summary to publish in the Federal Register stating:

1. SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF

FEDERAL REGULATIONS SECTIONS 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R.

91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407

(a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) CONCERNING COMMERCIAL OPERATION

OF DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MONDERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95) 2. NICE

PEOPLE, LLC dba TWICEINEVERYSPEED PHOTOGRAPHY is seeking exemption in order to
use the UAS for commercial use aerial image acquisition, including but not limited to, the

following industries: motion picture and television, commercial photography and advertising, real

estate, short range inspection, mapping and survey.

Sincerely,

Brandon Pierce

Nice People, LLC dba Twiceineveryspeed Photography

1053 Bennington Dr

Charleston, SC 29492

info@twiceineveryspeed.com

843­693­0915