### August	18,	2015

Sam	Hodge 4307	Murrells	Inlet	Road Murrells	Inlet	SC	29576 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CF R 91.119(c); 14 CFR 91.121; 14 C.F.R 91.145(b); 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(2); 14 CFR 91.417(a) and (b) To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11. I, Sam Hodge, operator of an Unmanned Aircraft System (UAS), DJI Inspire 1, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation o f its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner: • Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. • Aerial video and/or photography for public and/or private use including television, public/sporting events, cinematography, and news gathering. • Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

• Aerial vi deo/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. • The ability to offer training t o persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as f or the protection of the persons and property. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently usingconventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....esta blish requirements for the safe operation of such aircraft systems in the national airspace system.” The name and address of the applicant is: 

### Sam	Hodge 4307	Murrells	Inlet	Road Murrells	Inlet	SC	29576

Phone:	843	651

- 1874 email	Address: shodge@gtcounty.org

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 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 C.F.R 91.145(b) 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) Sam Hodge will operate the DJI Inspire 1, Model T600, with a total weight of 2935g or 6.47lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85inch. Under still air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 1 1m/s or 25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6

- cell 4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controller with an operating frequency of 2.400GHz

– 2.483GHz. The live video feed will have an operating frequency of 5.728GHz

– 5.850GHz. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative. The DJI Inspire 1 has an app called The DJI Pilot App which allows the Pilot to monitor all aspects of the flight on the HUD. Attached along with this exemption request are all of the necessary documents and safety features of the DJI Inspire 1. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s saf ety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited toreduced emis sions and noise, the grant of the requested exemption is in the public interest.

Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay. **AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commerci al operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 50mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). • Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 30% battery power reserve or 30 minutes of flight time whichever occurs first. • Flights wil l be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) a nd ma y include but not limited to a Camera Operator. • The UAS pilot will be a designated Pilot in Command (PIC) and hold a Commercial Pilot’s License. If the PIC feels another operator to be qualified with the necessary skills to be PIC & possess a Comme rcial Pilot’s License, that person may be designated PIC provided they have a minimum of 50 hours of flight time with the

UAS. • A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ prod uction activities. • All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an anemometer will be used prior to flight to measure wind speed, and atmospheric pressure in current flight location. • The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

• I f operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP) of a tow er controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.• The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. • The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. W ith the advanced permission of the FSDO, operations at closer range may be approved. • The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

 The PIC and VO will be able to comm unicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

• I f the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously. • The UAS will have the capability to abort a flight in cas e of unpredicted obstacles, weather, or emergencies. **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 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 H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of thes e criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The 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 operator and under the requirements and in compliance with local public safety requirements . The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subp art H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location of operation, lack of explosive materials or flammable liquid fuels, and

in ability to carry a substantial external load. **14 C.F.R. § 45.23 (b). Marking of the Aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport cate gory aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limi ted," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS m arked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.” **14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.** Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Sam Hodge may achieve an equivalent level of safety as ac hieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have a Private Pilot’s License along with a minimum of 50 hours of flight time which exceed the safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the safe operatio n of the UAS. **14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.** The regulation requires that no 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 ex emption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. Prop locks have been issued for this aircraft so the possibility of a prop flying off mid flight is inevitable which also achieves a higher safety factor. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.** Section 91.9 (b) (2) provides: No person may ope rate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual mat erial, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not onlybecause there is no pilot on board, but because there is no room or capacity to carry such an item

on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. If for some reason the Pilot forgets the fl ight manual, The DJI Pilot app has all documentation indicated in the hard copy manual, electronically built into the application on your smart phone or tablet. **14 C.F.R. § 91.103: Preflight Action.** This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedur es including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a home GPS location will be set for any reason the ai rcraft becomes disoriented in flight, and return safely to home. **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) that is being used for flight instruction unless th at aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio co mmunications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. **14 C.F.R. §91.119: Minimum Safe Altitudes.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be op erated at less 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 UAS that is a helicopter and the exemption requests authority t o operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the except ion that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted are a with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. It also may be operated over open water close to shore keeping a distance of 500 feet as indicated in Section 91.119 (c). The equiv alent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the prop erty owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between theseUAS o perations and the operations of conventional aircraft that must comply 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 i s set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of saf ety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The DJIInspire 1 uses DJI Vision Positioning. It is a po sitioning system that uses ultrasonic and image data to help the aircraft identify its current position. With the help of Vision Positioning, the Inspire 1 can hover in place more precisely and fly indoors or in other environments where there is no GPS signal available. The main components of DJI Vision Positioning are located on the bottom which include two sonar sensors and one monocular camera. This provides an significant level of safety. **14 C.F.R §91.145(b) Management of aircraft operations in the vic inity of aerial**  **demonstrations and major sporting events**

CFR 91.145 states: (b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or maj or sporting event not listed in paragraph (a) of this section, the FAA consi ders the following factors: (1) Area where the event will be held. (2) Effect flight restrictions will have on known aircraft operations. (3) Any existing ATC airspace traffic management restrictions. (4) Estimated duration of the event. (5) Degree of pub lic interest. (6) Number of spectators. (7) Provisions for spectator safety. (8) Number and types of participating aircraft. (9) Use of mixed high and low performance aircraft. (10) Impact on non

- participating aircraft. (11) Weather minimums. (12) Emergen cy procedures that will be in effect. If Sam Hodge intends to use the UAS to cover sporting events from outside the activity, 

### coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of an y other unmanned activities. Flight activity will be conducted based on safet y and with particular attention to the avoidance of overflight of large concentrations of people. However, specific relief from this regulation is still necessary to ensure compliance with FARs. **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 under VFR

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

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximate ly 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the 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 of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate give n the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 3 0 minutes or 30% of battery power

— whichever happens first. This restriction would be more than adequate to return the 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 Cert ification and Registration**  The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers o r crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will b e achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. Again if Pilot forgets documents, all documents can be achieved via the DJIP ilot App. **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 that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AG L. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Most importantly, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As p rovided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed. Additional Information The applicant, Sam Hodge, has been involved in piloting of remote controlled aircraft for more than 5 years and has an in

- depth understanding of the capabilities and safety concerns involved in using this technology as an asset to the community. The technology can be used in such a way that it benefits the community as a whole and can educ ate future pilots in a safe environment. The satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provides a level of safety that should be satisfactory to the FAA and general public. 

### Inview of the beneficial advantages to public saf

ety , I respectfully

submit my

Section 333 exemption request for allowing the commercial operation of the applicant’s UAS. Sincerely, 

### Sam	Hodge 4307	Murrells	Inlet	Road Murrells	Inlet,		S.C.	29576 shodge@gtcounty.org