U.S. Department ofTransportation, Docket Operations. West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590
March 25th, 2015
Re: Exemption Request Section 333 ofthe FAA Reform Act
U.S. Department ofTransportation,**~-** ---l-am-submitting-this-petition-on-my-own,**or~-the-behalf-of-my-com~JaRy bodoGir~ema;**  LLC. without the aid of legal council. Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, LodoCinema, LLC which is owned and operated by Michael Hering, a sole proprietor, operating in the State ofColorado. LodoCinema, LLC who has been shooting video in the state for the last 8 years and operating Small Unmanned Aircraft Systemsfor less than a year, wishes to apply for an exemption from the Federal Aviation Regulations (FAR) listed belowto allow operation of our sUAS commercially in airspace regulated bythe Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as may be established bythe FAA as required by Section333. The requested exemption would permit LodoCinema, LLC to pursue its commercial interests in providing services to companies interested in aerial data that can only be captured by using newlydeveloped sUAS in residential and public areas including but not limited to surveying, Real Estate aerial mapping, Agriculture crop assessment and growth patterns, Golf course management, Insurance company claim assessment, Special events, construction site and ecological-impact assessment

-----**-~bodoCir~ema,** LLC asserts that-al!-sUAS-f!ights-that-will-occur-over-private-or-controlled access property will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be in the area**wher~** flight activity is taking place. Additionally, I am a private pilot with 1 00 hours offlighttime logged and amthe sole operator ofthe sUAS we own and operate. Our observers will attend ground school to be taught the rules and regulation as they pertain to operating private aircraft underVisual Flight Rules (VFR) over civilian population areas as described and setfourth in the Aeronautical Information Manual.
The substance ofthis request is essentiallythe same as that granted to Falcon Sky Cam Requlatorv Docket No. FAA-2014-0884 in that LodoCinema, LLC is enqaqed in aerial photography of land, buildings, and insurance claims, by using remote controlled**~-**



# IsuA-=> to seetne conamon OTT1e1as, crops, ecoiogicai impact, and financiai iosses doto destruction byfire and other natural disasters, withoutthe need to drive over or climb on the property being so assessed. LodoCinema, LLC has equipped each of our sUAS aircraft GoPro cameras for aerial photoQraphy includinQ video and still pictures and special lens adaptations to makethem very accurate in the 3 D mapping activity. By doing so we have the abilityto produce high-resolution photography of remote locations that would be difficult or dangerous to reach on foot. This would be especially
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# ------!-- l -...1-r"'-!---- l I r" t-'1 VUIVIIIU\.1'"' t'V I II IV UVII**I~ IV~~**  VIUIIII YWVI r' lVI**Ill~**\.AI Ul IVY VVIIItJ'QI**IIC~. ~VUV'-"11**  ICIIIUJ**~'-""** exemption request would permit us to operate lightweight, unmanned (remotely controlled in line ofsight) sUAS's in tightly controlled and limited airspace. Predetermined, specifically marked areas ofoperation as well as Global Positioning**•~~-~~-_§atellite** (§PS)**na~igatioo** 

### !!lC!PS**~bich**incorgorate**restricted,.noJty~_4_0fJ~_s__an<;t,,G.Qr)tcoJ:=- ~-** **~-­** zones ofairports, will allow LodoCinema, LLC to operate within current safety parameters as well as the new ones being implemented. The Extentof Relief LodoCinema, LLC Seeks and Its Justification for Such Relief: Regulation from LodoCinema, LLC request exemption: 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.?(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 i4C.t=:i=1.8i.i5i(a) i4C.t=:i=1.8i.:205(i::>) i4C.t=:i=1.8i.:2i5 i4C.t=:Fi. (8i.40i-8i.4i7) Unmanned Aircraft System sUASs are seen as a better photographic platformto helicopters because these smaller devices are less expensive, they produce less noise, and they have much less environmental impact and are less likelyto cause injuryto the public and or property. I am petitioning for exemptionto enable LodoCinema, LLC to operate IRIS+, systems, 

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# --...t- r"-n-- U--- A Dl--1, ----·- TL...:- -1 1/\C" C'1Yit-'t-'YU YYI\.11 U 4 Q.AIW' 1<:.4.1 "'" '-CIIIIIrJUIJ UIIU <:.4. '"""""' I \J I lVI V ""TJ UIUVr\. vc;,u I lVI Uo I 111\oll**~VI\V** has a built in capacity to limitthe height it flies abovethe ground, to limit the radius of the distance it flies from the operator and to exclude itfor Class 8, C, and D airspace including No Fly Restricted Zones. The IRSI also hasthe failsafe feature ofthe Naza-M autopilot system which means when the communication between the main controller**~-** -and-the trarismitte-(is-los(the IRIS-will return to the home starting point and**1~md-safefy:~ ~~**  ,__ ThA**;::~hmJA ~nAr.ifir.;::~tinn~**  mAAt with thA MnrlAI**Airr.r;::~ft ()nAr;::~tinn** **~t;::~nrl;::~rrl~ ;::~~** **~At** I I oJ below:

• The petitioner will only operate its sUAS in line ofsight ofa pilot/observer and will

operate at sitestnat are sumcient distance from popuiated areas witnin tne steriie area described in the FOPM. Such operations will insure that the sUAS will not create a hazard to users ofthe national airspace or the public. • When flyinQ sUAS within 3 miles ofan airport, airport operators will be notified and the

operator will give the right ofwayto avoid flying in the proximity offull scale aircraft. • Maximum flight time for each operational flight will be 30 minutes.• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. • The sUAS will be programmed so it will not be operated at an altitude of no more than

4oo feetAGL, and not more than 200 feet above a fixed platform from which operations are conducted. • The minimum crew for each operation will consist ofthe sUAS pilot and the Visual

Observer. • The sUAS will weigh lessthan 55 pounds including its payload of camera and gimbal. • The sUAS will fly no more than 50 knots and can hover plus move horizontally and

vertically. • Given the small size ofthe sUAS, and the restricted airspace within which it will

operate, I believe our**sUA~ oR_eration.s_wiiLc.QmpJy_wi.tb_bothJhe_spi~itand-tbe.rules.-:-:-:------**  - 

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### -· intended bythe Reform Act safety requirements. I respectfully request exemption under Section 333to enable LodoCinema, LLC to operate efficient, limited, lowrisk commercial sUAS operations for the activities stated, respecting at all times, the space and privacy ofcitizens and property as we keep our skies safe. Sincere!, Michael Hering LodoCinema, LLC 450 w 14th ave 40243 Denver, CO 80204**~--** 

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