July	25,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue	SE

Washington,	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act –	Request	for	Additional	

Information

Dear	Mr.	Robeson,	

Please	find	enclosed	in	this	letter	the	requested	additional	information.		

In	your	letter	dated	June	26,	2015,	you	requested	further	reasons	why	the	

exemption	would	not	adversely	affect	safety	or	how	the	exemption	would	provide	a	

level	of	safety	at	least	equal	to	that	provided	by	the	rule	from	which	I	seek	an	

exemption.		

The	commercial	service	that	I	(Blackhound	Creative	Werks)	would	like	to	provide	

would	be	photography	and	videography	of	real	estate	property	and	special	events.		I	

would	be	flying	the	sUAS	within	the	guidelines	of	the	exemption,	no	higher	than	200	

feet,	not	within	5	nautical	miles	of	an	airport	reference	point,	and	only	with	prior	

approval	from	the	property	owner	or	event	holder.		

I	will	be	utilizing	the	DJI	Phantom		2	Vision	Plus	with	GPS	safety	features	to	limit	the	

ability	of	flight	altitude,	the	radius	of	flight,	and	a	no-fly	zone	feature	to	restrict	

flying	in	unallowable	airspace.			The	sUAS	features	a	trigger	system	in	the	event	

communication	is	lost	between	the	transmitter	and	the	sUAS	that	automatically	

returns	the	sUAS	the	home	point	set	at	the	time	of	initial	flight.		

I	will	be	utilizing	pre	and	post	inspections	flights	on	the	aircraft	to	ensure	all	proper	

mechanics	are	in	place	to	ensure	safe	flight	of	not	only	the	aircraft,	but	also	the

surrounding	areas.		
The	purpose	of	the	request	is	to	provide	data	(via	photography	and	videography)	to	

local	real	estate	professionals,	builders,	and	developers	to	enhance	marketing	

efforts	and	assist	in	inspections..

The	use	of	the	sUAS	by	Blackhound	Creative	Werks	will	not	adversely	affect	the	

safety	of	the	public	because	it	will	be	utilized	within	the	restrictions	of	the	

exemption	and	will	always	be	flown	within	my	line	of	sight	and	with	a	visual	

observer.			The	use	of	sUAS	will	provide	a	level	of	safety	higher	than	that	of	a	

helicopter	or	other	aerial	data	performing	the	same	mission	due	to	it’s	lightweight	

size,	performance	capability,	reduced	noise,	and	smaller	environmental	impact.		

The	maximum	flight	time	for	each	operation	will	be	30	minutes.		Flights	will	be	

terminated	when	battery	levels	reach	25%,	allowing	sufficient	reserve	flight	time	to	

safely	land	the	sUAS.

Minimum	crew	for	each	operation	will	consist	of:	sUAS	pilot	and	visual	observer.		

The	sUAS	operated	by	the	petitioner	weighs	less	than	25	pounds,	including	all	

payload	(ie:	camera,	lens,	&	stabilized	gimbal).		The	sUAS	will	operate	at	speeds	no	

more	than	50	knots,	can	hover,	and	can	simultaneously	move	vertically	and	

horizontally.			Given	the	small	size	of	the	sUAS	and	the	restricted	sterile	

environment	within	which	it	will	operate,	Blackhound	Creative	Werks’	operations	

adhere	to	the	Reform	Act’s	safety	requirements.	

We	respectively	request	exemption	under	Section	333	to	enable	Blackhound	

Creative	Werks	to	operate	efficient,	limited,	low-risk	commercial	sUAS	operations	

for	the	activities	stated	respecting	at	all	times	the	space	and	privacy	of	citizens	and	

property	while	keeping	airspace	safe.

Sincerely,

Kristen Brumbaugh 

Kristen	Brumbaugh

Blackhound	Creative	Werks

328	Bluestem	Drive

Elgin,	SC	29045

803-665-9136

Kristen@blackhoundcreative.com