VincentJ. Barnhart A

-GAdvertising Graphics Inc. 190 North Union StreetSuite 100 Akron, Ohio 44304 November 11 , 2015 U.S. DepartmentofTransportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Forward: In an attempt to make sure that I , VincentJ
. Barnhart, am familiar and abiding by all flight standards, I've taken it upon myselfto enroll, and complete Patricia Austin's "Curious About Flying" course atthe Discover Aviation Center at Lorain County Regional Airport in Elyria, Ohio
. Patricia Austin is an Advanced Ground Instructorwho has nearly 30 years offlying experience and aviation knowledge and is the Owner of"Curious About Flying". Her course covered Federal Aviation Regulations (FARs), airspace denotations, chartreading, distinguishing and understanding radio transmissions, how to communicate with the control tower prior to flight, as well as many other topics. In addition to Patricia Austin's course, I've Jogged nearly 100 flights, covering about 50,000 Meters, equivalent to over 30 hours offlight time with my UAS at an extremely low altitude (5-10 feet) in an unobstructed field, learning control maneuvers, radio Joss contingency plans, as well as safety regulation checklists prior to every flight, withoutincident In addition, I've completed "Flight Training" tutorials presetwithin my UAS thatwould better familiarize me with all flying instruments, actions ofthe objectitself, as well as it's maneuverability. Itwas importantto me to learn every aspect ofmy UAS prior to leaving the ground anymore than my own height. Since regulations have changed, I have rejected workfrom many clients because my drone was notyetregistered, and this paperwork notyet submitted, to be in accordance with FAA regulations. Ihave, however, contacted local law enforcementfor the cities ofHudson, Stow, Akron, Cuyahoga Falls, Tallmadge, and Hartville, Ohio, to letthem know ofmy services and availability (once FAA approval is granted) to donate my time in the unfortunate event ofa missing person search. Iwish to use my drone commercially, butalso realize that flying is a privilege thatwill notonly benefit my clients, butalso the surroundingcommunity in the state ofOhio. End Forward. Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45
.23(b); 14 CFR 61.113(a) ; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91
.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91
.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a) ; 14CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

### To whom it

### may concern: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11 , Vincent

### J .Barnhartowner ofA-G Advertising Graphics, hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation ofa small UAS, so long as such operations are conducted within and under the conditions outlined herein or as my be established by the FAA as required by Section 333, for all operators ofsmall Unmanned Aerial Systems (UAS) working for Advertising Graphics
. Commercial operation small UAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner: 1. Aerial photography and/or video for public andjor private use including real estate, architecture, land surveying, engineering and otherrelated professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, and cinematography. 3. Aerial inspection/photography ofresidential/commercial structures under contractwith the owners or local governmentauthority. 4. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or governmenthas requested it by contractordonation
.As described fully below, the requested exemption would permit the operation ofsmall 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 industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "
....establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." 

### The name, phone, email and address ofthe applicant: Name: A-G Advertising Graphics Inc. Phone: (330) 535-2525 Email: vince@adgraphicsinc.com Address: 190 NUnion Street Suite 100 Akron, Ohio, 44304 

### Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14CFR45.23 (b) 14 CFR 61.113(a) 14 CFR 91
.7 (a) 14 CFR 91
.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### &(b) The small UAS's Iwill be using are multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds ofno more than 45 Mph or 39 Knots and have the ability hover and move along a vertical and horizontal plane simultaneously. They will operate in line ofsight only and by the exempted persons only obeying all other local and federal laws. Given the small size ofthe small UAS and the controlled environment provided the proposed operations will adhere to the Reform Act's safety requirements
. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but notlimited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly the applicantrequests thatthe FAA grantthe requested exemption with minimum delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The small UAS will weigh less than 55 lbs
. 2. Flights will be operated within line ofsight ofa pilot and/or observer
. 3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight time whichever occurs first. 4. Flights wiH be operated at an altitude ofno more than 400 feet Above Ground Level (AGL) and not more than 200 feetabove an elevated platform from which filming is planned. 5. Minimum crew for each operation will consistofthe small UAS Pilot in Command (PIC), the Visual Observer (VO) when needed and may include butnot limited to a Camera Operator. 6. A briefing will be performed regarding the planned small UAS operations prior to each day's flight consisting ofall the days' production activities
. 7. The PIC will obtain verbal/written consentofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required under the FOM
.With the advanced permission ordirection of the FSDO, operations at closer range may be approved
. 8. The PIC and VO will have been trained in operation ofsmall UAS and receive up-to-date information for the particular small UAS to be operated and will be able to show upon requesttheir competentability to operate the small UAS and/or Camera. 9
.The PIC and VO will be able to communicate by voice, radio, and/or textat all times. 10. Written and/orverbal permission and permitswill be obtained from territorial, state, county orcityjurisdictions, including law enforcement, fire or otherappropriate governmental agencies when needed
. 11. Ifthe small UAS loses communications or loses GPS signal, the small UAS will have the capability to return to a predetermined location within a designated location and land autonomously
. 12. The small UAS will have the capabilityto abort a flight in case ofunpredicted obstacles, weather, or emergencies
. 13. Within the flight system programming ofthe DJI Phantom 3, the UAS will not allow a pilot to travel above 400 feet, regardless ofthe pilots wishes. In addition to these FAA guidelines being programmed into the Phantom 3 UAS, the UAS is programmed to be unable to lift offifit is within the five miles radius ofan airport
. Being thatthese are programmed into the flight system ofthe UAS, Ibelieve this makes itextremely safe. 15. In the unlikely eventofan unscheduled landing/crash, this UAS poses no threat offire to land orwildlife as the UAS does notcontain any combustible fuel, butis powered by DJI LiPo battery
. 

### 14C.F.R. Part21, SubpartH: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exemptaircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular small UAS
. In all cases, an analysis ofthese criteria demonstrates thatthe small UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The small UAS to be operated hereunder is less than 55 lbs
. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operatorand under the requirements and in compliance with local public safety requirements
.These safety enhancements provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F
.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the small UAS, due to its size, speed of operation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

### 14C.F.R. § 45.23 (b). 

### Marking oftheAircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on thataircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable
. Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the small UAS will haveno entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe small UAS, two-inch letteringwill be impossible. The word "Experimental" as well as theN Number registered with this aircraft (N1227V) will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided byhaving the small UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the small UAS will see the identification ofthe small UAS as "Experimental- N1227Y". 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilotin Command. Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilotin command ofan aircraft thatis carrying passengers or property for compensation or hire. Our small UAS do not carry any pilots or passengers nor propertytherefore I am seeking an exemption to 14 CFR 61.113(a)
.Although helpful, a pilot's license will notensure remote control piloting skills. The risks attendantto the operation ofsmall UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. Ifeel the operation and limitations setforth in the FOM will equate to the safe operation ofthe small UAS. 14 C.F.R. §91.7(a): Civil AircraftAirworthiness. The regulation requires thatno person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and use ofsafety checklists prior to each flight an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 

### (b) (2}: Civil Aircraft Flight Manual in theAircraft. Section 91.9 (b) (2) provides: No person may operate a U.S
.-registered civil aircraft
... (2) For which anAirplane or Rotorcraft Flight Manual is notrequired by §21.5 ofthis chapter, unless there is available in the aircraft a currentapproved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof
. The small UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, butbecause there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilot flying the small UAS will have immediate access to it. 14 C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The OPERATOR will take all actions including reviewing weather, flight batteryrequirements, landing and takeoffdistances and aircraft performance databefore initiation offlight. Prior to flight, withoutexception, calibration ofthe GPS system will be achieved by the PIC. Priorto flight, without exception, PIC will nottake offwithouta "Safe to Fly" reading on the UAS remote which is achieved by calibrating the UAS with up to (atleast) 8 satellites which helps control flight regardless of wind or otherexternal interference. In addition to these features, this UAS is programmed, in the event ofa lost signal to the RC, to return backto "home" which is established from it's takeoffpoint priorto every flight. 14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) thatis beingused for flight instruction unless that aircrafthas fully functioning dual controls
. Small UAS and remotely piloted aircraft, by their design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications
. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft
. Section 91.119 (d) allows helicopters to be operated atless than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a small UAS thatis a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption maybe needed to allow such operations. As setforth herein, the small UAS will never operate at higher than 400 AGL with the exception that in circumstances where the small UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the small UAS will notbe operated more than 100' above the highest point

### on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will notbe exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe small UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials
. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraftweighting far more than the maximum 551bs
. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraftoperating at orbelow 500 AGL. In addition, the low-altitude operations ofthe small UAS will ensure separation between these small-UAS operations and the operations ofconventional aircraft thatmustcomply with Section 91.119
. 14 C.F.R. §91.121 Altimeter Settings. 

### This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
... to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. Programmed beneath the UAS is an onboard sonar system which will allow PIC to see accurate elevation ofthe UAS as well as extremely accurate GPS location (within 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

### Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first pointofintended landing, and, assuming normal cruising speed-(1) During the day, to fly after that for at least 30 minutes; or {2} At night, to fly after that for atleast 45 minutes
."The batterypowering the small UAS provides approximately 30 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length
. Given the limitations on the small UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight or twilightVFR conditions is reasonable. Applicant believes thatan exemption from 14 CFR §91.151{a) falls within the scope ofprior exemptions. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does notengender the type ofrisks that Section 91.151{a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting small UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted
.Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbatterypower-whichever happens first. This restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and 

### (b): Carrying Civil Aircraft Certification and Registration 

### The regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas within it the following: (1) An appropriate and current airworthiness certificate
.... (b) No person may operate a civil aircraft unless the airworthfness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The small UAS fully loaded weighs no more than 55 lbs. and is operated without an on board pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the small UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the small UAS will have immediate access to them; to the extentthey are applicable to the small UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

### These regulations require that an aircraft operator or owner "shall have thataircraft inspected as prescribed in subpartE ofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter
...," and others shall inspect or maintain the aircraft in compliance with Part43. Given thatthese section and Part43 apply only to aircraftwith an airworthiness certificate, these sections will notapply to the applicant Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalentlevel ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the small UAS can land immediately and will be operatingfrom no higher than 400 feet AGL. The operatorwill ensure thatthe small UAS is in working order priorto initiating flight, perform required maintenance, and keep a Jog ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalentlevel ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM}
. As provided in the FOM, the operatorwill ensure thatthe small UAS is in working orderprior to initiating flight and perform required maintenance needed
. Small UAS Information Small UAS's to be used are as follows butnotlimited to providing they are within the scope ofthe exemption granted by the FAA: DJI Phantom 3 • Weight (Battery & Propellers Included)- 2.8211bs. • Hover Accuracy- Vertical:+/-.33ft (when Vision Positioning is active) or +/-1.64ft Horizontal: + /-4
.9 ft • Max Yaw Angular Velocity- 200° 

### js • Max Tilt Angel

- 35° • Max Ascent Speed- 16 ft/s • Max Descent Speed- 9 ft/s • Max Flight Speed- 36mph DJI Phantom 3 Transmitter • Operating Frequency- 2.400GHz

- 2.483GHz • Communication Distance (unobstructed)- FCC Compliance: 2400 ft • Receiver Sensitivity (1%PER) -101dbm + /-2dbm • Transmitter Power -FCC Compliance: 20dbm CE: 16dbm DJI Phantom 3 Battery • DJI 4480mAH LiPo Battery HD Video Recording (Field ofView -110°/85°) • UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 • FHD: 1920x1080p 24/25/30/48/50/60 • HD: 1280x720p 24/25/30/48/50/60 DJI Phantom 3 Gimbal • Controllable Range-Pitch -90 degrees to +30 degrees • Stabilization-3-axis (pitch, roll, yaw) DJI Phantom 3 Camera • Operating Temperature Range -32°F -104°F • Sensor Size -1/2.3 in
. • Effective Pixels -14M • Resolution -4384x3288 Conclusion Thankyou for the consideration ofthese exemptions, Sincerely,

VincentJ
. Barn art Owner/Operator /PIC A-G Advertising Graphics Inc.