February 9th, 2016

U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590 Antigravity Photography LLC 507 Timothy Lane

Cuba, Mo 65453

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Antigravity Photography LLC, seeks an exemption from Federal Aviation Regulations ("FARs") detailed below forthe following described Unmanned Aerial System called in this application the ME System, which includes an UnmannedAircraft (UA) and ground station-based equipment and crew:

THE UNMANNEDAIRCRAFT (UA):


## 0 A lightweight (20 lb gross weightwith all on-board equipment), manufactured by DJI, Phantom 3 Professional, and Inspire 1that includes the following equipment in flight; 

## 0 An on-board flight computerwith GPS navigation and location abilitythat receives signals for flight controls from a ground-based transmitter/controller;

### ~ An on-board camera capable ofcapturing imagery in the form offull color, high definition still photos and video; 

## 0 An on-board telemetry system that delivers flight data from the on-board flight computerto the on-board radio transmitter including altitudeAGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site; 

## 0 A 2.4GHz on-board radio transmitterthattransmits livevideo from the on-board camera plus all the flight data from thetelemetry system described above;THE GROUND STATION -BASED PART OF THE SYSTEM:

### It~ A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAwhile in the air;

### it~ A 2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight; 

## ltl A radio receiver receiving live video and flight data from the on-board camera and computer projects itall together onto a screen forthe PIC toview during flight; 

## 0 A Visual Observer (VO) is a person who provides a second pair ofeyes tovisually track the UAwhile in flight.

The requested exemptionwould support an application for a commercial Certificate of Authorization to usethe above described ME System to support aerial photography and video primarily of real estate property, resorts, hotels, community events and closed film sets, never operating over persons not directly involved with the ME system.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flighttime of only 25 minutes, this is offers little or no riskto national security.

Low level oblique photos and video from several angles are far more effective than ground based imageryfor displaying the characteristics of large, complex properties with several buildings and largetrees. The alternative could beto charter a full-sized helicopterforthis purpose, which has proven more costlythan many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property.
Additionally, we requestthatwe be allowed to use our system to benefit first responders nearby who might require assistance, including fire-fighters, the police, the sheriff, et al., while remaining subjectto all limitations cited in this application as we do so.

The ME System will be operated in the field with both a PIC and aVO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:
a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no morethan 400ftAGL, at an airspeed of no morethan 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation;d) Operationswill be restricted to flights over property with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilotwith a similar UAtype; 

### f) All required permitswill be obtained from state and local government priorto operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly ofpeople; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM ofan airport orheliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) Noflight may be made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe forflight {see Appendix A).

The PIC and VOwill meetthe requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VOwill perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.

We submitthatthe combination ofthe UA's lightweight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions {a) through {n) listed above, the FAA can havefull confidence that the operation will have an equivalent orgreater level ofsafety than manned aircraft performing the
same mission.

The name and contact information ofthe applicant are: dbaAntigravity Photography :Adam Wilson Ph: 661-755-2848 Email: awilson448811 @gmail.com

The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith our proposed equivalent level ofsafetyfor each regulation:

- 14 CFR Part 21

................................. Addendum Page 1

- 14 CFR 91.203

.................................Addendum Page 1

- 14 CFR45.23, 45.29

..........................Addendum Page 2

- 14 CFR 91.9

....................................Addendum Page 2

- 14 CFR 61.113, 61.133

.......................Addendum Page 2 -14 CFR 91.109, 91.119, 91.121

..............Addendum Page 3

- 14 CFR 91.151

.................................Addendum Page 3

- 14 CFR Subpart E (91.401- 91.417)

......Addendum Page 3 -FAA Policy 8900.227 Paragraph 16{c){4) and Paragraph 16(e)(1)

...Addendum 1We are prepared to modify oramend any part ofthis request to satisfythe need for an equivalent level ofsafety. Please contact us at anytime ifyou require additional information or clarification. We lookforward to working with your office.
Sincerely,

# A~~
Adam Wilson, Antigravity Photography LLC,

Addendum containing Exemption Requests and Equivalent Level ofSafetyAppendix A - Flight Manual's Appendix 8 - Owner's Manual for UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Antigravity Photography LLC, requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe ME System:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. Whilethe FAA continues toworkto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System undereither or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment,
new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate majordesign changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be usedfor commercial purposes such as market surveys, sales demonstrations, and customer crew training, wewould expect that an experimental certificate would permit our commercial purpose as well. The aircraftwill not carry persons or property, will not carry fuel, and will onlyfly under strict operational requirements. Combinedwith the UA's lightweight, being constructed primarily of carbon fiber and plastic, we proposethat the UAwill be at least as safe, ifnotsafer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level ofsafety outlined inthe previous paragraph.

14 CFR 91.203(a) 

### &(b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration numberassigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be

..displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum grossweight of6.5 pounds, the UA istoo small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documents deemed appropriate forthis aircraft bythe FAAwill be co-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed tothe aircraftvia placard containing the following information plus theword "EXPERIMENTAL" to satisfythe requirement of 14 CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: DJIInnovations, Inc. 950 E Baseline Ave. Ste. 210 Apache Junction AZ 85119 Model: Inspire 1 and Phantom 3 professional

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word**~~EXPERIMENTAL"** in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it bythe FAA. We proposeto achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity ofthe aircraftwhile it is preparing for launch will be ableto see the designation. Additionally, wefeel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or bannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraft will operate within 3/4 NM ofthe ground station, the bannershould be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.

14 CFR 91.9 Civil aircraft flight manl)al, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew atthe ground station anytimethe aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command ofan aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act
as pilot in command ofan aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require thatthe PIC musteither

1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours offlight experience in this type of UA, or 2. Meetthe requirements of8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" inwhich the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilotwritten examination." Since there are currently no means available forthe pilot ofa UAS to gain the experience in an equivalent category and class in orderto applyfora commercial pilot's license, we propose to generate an equivalent level ofsafety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition
Appendix A to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, wefeel we meetthe intent of61.113 Subparagraph (b) even though the intent ofthis application isto conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flighttests The regulation states that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fully functioning dual controls." The ME System ground-based control station consists ofa small hand-held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set ofcontrols simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level ofsafety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that oversparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of400 feet AGL, we cannot complywith this requirement. In orderto provide an equivalent level ofsafetywewill only fly over private propertywith a size ofat leasttwo acres with the permission ofthe owner ofthe property flown over. The aircraftwill not be operated over congested areas or over any open air assemblyofpersons. The property
ownerwill be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraftwill be operated at a low altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that duetothe small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting availablewithin 100 NM ofthe aircraft. The UAwill always fly below 400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflictwith other aircraft. AnAbove Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on-board computerto the display
screen held by the PIC, providing a constantly updated AGL readout.14 CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unlessthere is enough fuel to fly to thefirst point of intended landing andtofly after that for at least 30 minutes. Wefeel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The UA is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20o/o reserve. Since the aircraftwill neverfly morethan 31'4 NM from the point of intended landing, a full battery charge at launchwill ensure thatwe meet

### the reserve energy requirement ofthis paragraph. We request
an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 • 91.417)

... Maintenance, Preventive Maintenance, Alterations The regulation providesthat the operator is primarily responsible for maintaining the aircraft in
an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct
Appendix A detailed inspections aftereverytwo hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on.-board computer. All other maintenance will be performed by the manufacturerortheir designated repairfacility. The PIC will documentwork performed in accordance with 91.417. Wefeel that duetothe size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level ofsafety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UA maximum gross weight is 6.5 pounds, it is constructed ofcarbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslytothe site of launching and landwithout crew intervention.

Therefore, requiring the PIC and VOto meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose thatthe minimum medical requirements forthe PIC and VO bevision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle.Appendix A

APPENDIXA- FLIGHT MANUAL

FLIGHT RESTRICTIONS a) Noflightwill be madewith a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no morethan 50 knots and nofurtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted to flights over propertywith the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilotwith a similar UAtype; f) All required permitswill be obtained from state and local government priorto operation; g) The ME System will not be operated overdensely populated areas; h) The ME System will not be operated at airshows; i) The ME System will not be operated over any open-air assembly ofpeople; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM ofan airport or heliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PICwill brieftheVO and property owner aboutthe operation and risk before the first flight at each new location; n) Noflight may be madewithout a successful Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UA is in a condition safe forflight.

PREFLIGHTCHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted 

### if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected tothe aircraft.

TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Homefeature is activated and will bring the UAV back to the PIC.