September 14, 2015 U.S Department ofTransportation Docket Operations 1200Jersey Ave, SE West Building Ground Floor Room W12-140 Washington, D.C 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act of2012 Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and C.F.R. Part 11, Action Sports Media, LLC owner and operatorofSmall Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FARs) listed below so Action Sports Media, LLC may operate UASs commercially in airspace regulated by the Federal Aviation Administration; as long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by section 333 The Name and address ofthe applicant is:

. Action Sports Media, LLC Attn: Taylor Dockins 1503 N 6th Street Coeur d'Alene, ID 83814 taylor@asml080.com (208)306.1024 As described below, the requested exemption would permitthe operation of lightweight (less than 55 lbs total take offgross weight) UASs under controlled conditions for commercial use by professional certificated pilotsthereby enhancing safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

.... establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. Action Sports Media, LLC respectfully requests the grant ofan exemption to the following specific sections oftheTitle 14 Code offederal Regulations allowing itto operate lightweight UAS's for commercial use: 14CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) &(b) Action Sports Media, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR's operatingto preventAction Sport Media,·LLC's futurEicommercial use ofsmall UASs to operate in the national airspace system as described below: The Reform Act Section 332 provides for such integration ofcivil unmanned aircraft systems into our.national airspace system as it is in the public's interestto do so. Actions Sports Media,

.,. ....**~**.. ; .LLC's lightweight UASs: OJI Phantom 

### 2, OJI Phantom 3 Pro and OJI Inspire meetthe definition of"small unmanned aircraft" as defined in section 331 and therefore the integration ofAction Sports Media, LLC's lightweight UASs are expressly contemplated by the Reform Act. Action Sports Media, LLC would like to operate its lightweight UASs priorto the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required underSection 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose athreat to national security in light ofthe following:

• The UAS's size, weight, speed and operational capability • Operation ofthe UAS in close proximityto airports and populated areas • Operation ofthe UAS within visual line ofsight ofthe operator Reform Act 333 (a) Ifthe secretary determinesthat such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the National Airspace System." Action Sports Media, LLC's UAS's are rotorcraftweighing less than 55 pounds including payload. They operate ata speed of less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will operate onlywithin the line ofsight ofthe pilot within a protected flight area as described below. Such operations will insure thatthe UASs will not create a hazard tothe users ofthe national airspace system orthe public. The small nature ofthe UASs utilized: DJI Phantom 

### 2, DJI Phantom 3 Pro and DJIInspire, by Action Sports Media, LLC combined with the safety protocols outlined belowwill allowfor a greaterthan equivalent level ofsafety in which Congress envisioned thatthe FAA must, by exemption allowcommercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the areas and altitudes theywill operate, approval ofthe exemption presents no national security issue and absolutely minimal safety concerns which have been mitigated through a rigorous risk management process. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, the significant public benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional aircraft as well as the economic impact ofgreatly reducingthe cost ofaerial photography thereby benefitingthe greater public's interest. Accordingly, the applicant requests thatthe FAA grant the requested exemption without delay The following limitations are considered to be binding forthe operation of UASs for commercial purposes byAction Sports Media, LLC: 1. Flights will be operated in the line-of-sight by a ground-based pilot 2. Flights will onlyoccur in the daytime and clear ofclouds 3. The UASs will weigh less than 551bs attake-offand during flight 4. Flights will be terminated with 25% ofbattery life remaining 5. Flights will be operated at an altitude at or below 400' AGL14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in theAircraft 14 C.F.R. 91.9(b)(2) requires an aircraftflight manual in the aircraft. As there are no pilots ofpassengers, and given the size ofthe UASs, this regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining an operator manual at the flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 

### 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 

### 10167, 10167A, 10602, 10700 and 32827. 14C.F.R. 91.103{b) PreflightActions 14 C.F.R. 91.103 Each pilot in command shall, before beginning aflight, become familiarwith all available information concerning thatflight. This information must include: (b) For anyflight, runway lengths at airports ofintended use, and the followingtakeoffand landing distance information. This subparagraph is not applicable due to our 

### offairfield operations. 14C.F.R. 91.109 Flight instructions; simulated instrumentflight and certainflighttests. 14 C.F.R. 91.109 and all the subparagraphs address the operation ofacivil manned aircraft in conjunction with training and flighttests. The UAS to be employed by Action Sports Media, LLC are not designated in this category. 14C.F.R. 91.121 Altimeter Settings 14 C.F.R. 91.121 regarding altimetersettings is inapplicable because Action Sports Media, LLC's UASs utilize GPS systems and internal gyroscopes to provide spatial stability and a reference datum. 14C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions 14 C.F.R. 91.151 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 point of intended landing, and assuming normal cruising speed. The battery powering the UAS provides approximately 15 minutes ofpowered flight, which is less than the reserve requirement alone by FARs for day. Given the !imitations on the UAS's flight envelope, proposed AOR size, battery life and its abilityto land immediately it is reasonable to allow an exception An equivalent level ofsafety can be achieved by limitingflights to 25% ofbattery power. This restriction would be more than adequate to return the UAS to its planned landing zone in the AOR. Similar exemptions have been granted to otheroperations, including Exemptions 2689F, 5745, 10673 and 10808. 14C.F.R. 45.23 Markingofthe Aircraft Applicable Codes of Federal regulations require aircraftto be marked according to certain specifications. Action Sports Media, LLC UASs are unmanned; do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is impractical to place on such small aircraft. Action Sports Media, LLC will, however, place the word "EXPERIMENTAL" on its fuselage as required by14 C.F.R. 45.29 (f) so thatthe pilot, camera operator, observer and any other persons operating in the AOR can see the markings on the UAS. The FAA has previously issued exemptionsto this regulation through Exemptions Nos. 8738, 10167, 10167 A, and 10700. 14C.F.R. 91.119 Minimum Safe Altitudes 14C.F.R. 91.119 prescribes safe altitudesforthe operation ofcivil aircraft. It allows helicopters to be operated at loweraltitudes in certain conditions. Action Sports Media, LLC will only operate its UASs at or below400AGL. Action Sports Media, LLC will operate its UASs in a defined AOR that has been carefully reviewed for hazards and minimizesthe presence ofany persons notessential for operations. Flights will only be conducted over private propertywith consent ofthe property owner. The equivalent level ofsafety will be achieved given the size, weight and speed ofthe UAS as well as the location where it is operated. Compared to flight operations with traditional aircraft or rotorcraftweighing far more than SSibs, operating below 500 AGL with flammable fuel UAS operations present afar smaller risk. 14C.F.R. 91.405 

### (a), 407 (a)(1), 409(a)(2), 417(a) 

### &(b) Maintenance Inspections These regulations require that an aircraft operatororowner "shall have the aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as prescribed 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 Part 43. These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Action Sports Media, LLC UASs should its requested exemption be granted. As an equivalent level of safetyAction Sports Media, LLC requires its pilotsto conduct a preflight, through flight and postflight inspection ofthe UAS to ensure its flight worthiness priorto launch. Each UAS is flown in compliance with the applicable manufactures manual to include all software update cycles as well as flight checklists. In the event ofa malfunction the UAS can land immediately. Privacy All flights will occur over private orcontrolled access propertywith the propertyowner's priorconsent and knowledge. Conclusion Action Sports Media, LLC is seeking exemption from the following rules: 14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7{a), 91.9 {b)(2), 91.103{b), 91.109, 91.119, 91.121, 91.151{a), 91.203{a)&(b), 91.405(a), 91.407{a){1), 91.409{a)(2), 91.417{a)&(b). Approval ofthe above exemptions allowing commercial operations ofsmall UASs in the service ofaerial photographywill greatly enhance safety by reducingthe overall risk associated with traditional aircraft. Traditional aerial photography and videography requires large aircraft weighingthousands of pounds and carrying hundreds of pound offuel presenting a significant risk to life and property. With Action Sports Media, LLC's use ofsmall UASs weighing less than 55 lbs, powered by batteries and operating at or below400 AGL, theyvirtually eliminate all ofthe risk associated with traditional aerial photography and videography. The UASs will carry no people thereby eliminatingthe exposure to the risks associated with flying while accomplishing the same task in a much safer manner.GrantingAction Sports Media, LLC the above exemptions will allow forthe expansion of UAS systems into the future, in a professional, safety conscious culture steep in ourfoundation. The safety culture established by Action Sports Media, LLC is based on ourseveral years ofbusiness experience and caution for public safety and awareness of UAS's. Action Sports Media, LLC respectfully requests that the FAA grant its exception without delay. The FAA has the authorityto issue the exemption sought by Action Sports Media, LLC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Sincerely,



# -----**~** c--· IC0il<N'**~**c

### K·~**I\..~** v Taylor Dockins Action Sports Media, LLC 1503 N 6th Street Coeur d'Alene, ID 83814 taylor@asm1080.com {208)306.1024