Forever Ready Productions, LLC

465 S Main Street #304 Memphis, TN 38103 Scott@ForeverReadyLLC.com (cell) 901-729-9215 July 24, 2015

US Department Of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or Madam:

Pursuant to Secti on 333 of the FAA Moderni zati on and Reform Act of 201 2(the reform act) and CFR Part 11, Forever Ready Productions, LLC

, owner and operator of Small Unmanned

Ai rcraft Systems (UASs), request to be exempted from the Federal Avi ati on Regul ati ons {FAR) listed bel ow so that Forever Ready Productions, LLC may operate UASs co mmercially in airspace regulated by the FAA, as long as such oper ations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Forever Ready Productions, LLC is co-owned by Scot t W Ready and Lauren M Ready. Forever Ready Productions, LLC will secure a PIC as operato r with appropriate licensure as stipulated by the Section 333 exemption requirements. All operations performed will be performed with public’s safety and right to privacy safe-guarded at all times.

As described below, the requested exception would p ermit the operation of light weight (less than 55 lbs. total takeoff weigh t) UASs under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation's ( the FAA Administrator's) resp onsibility to" establish requirements for safe operation of such aircraft systems in national airs pace systems." Section 333(c), of the Reform

Act.

Forever Ready Productions, LLC video UASs are rotor craft weighing less than 55 pounds including payload. (The DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire class) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. UASs have an a uto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area

as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.

Forever Ready Productions, LLC respectfully request s the grant of an exception to the following specific sections of the Title 14 Code Fe deral regulations a11owing it to operate lightweight UASs for commercial use,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)&(b).

Forever Ready Productions, LLC submits this applica tion in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any c urrent applicable FAR’s operating to prevent Forever Ready Productions, LLC future commercial us e of small UASs to operate in the national airspace system (NAS) as described below. The Refo rm Act section 332 provides for such integration of civil unmanned aircraft into our NAS as it is in the public’s interest to do so. Forever Ready Productions, LLC’s UASs meet the defi nition of “small unmanned aircraft” as defined in Section 331 and therefore the integratio n of these UASs are expressly contemplated by the Reform Act. Forever Ready Productions, LLC would like to operate its light weight UASs prior to the time period by which the Reform Act re quires the FAA to promulgate rules governing such aircraft.

The Reform Act direct the Secretary of Transportati on to consider whether certain unmanned aircraft systems may operate safely in the national airspace before completion of the rule making required under Section 332 of the R eform Act. In making this determination, the Secretary of Transportation is required to dete rmine which UASs do create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

- The UASs size, speed, weight and operational capabi lity

- Operation of the UASs in close proximinity to airpo rts and populated areas

- Operation of the UASs within visual line of sight o f the operator

Reform Act 333(a). If the secretary determines tha t such vehicale “may operate safely in the national airspace system, the secretary shal l establish requirements for the safe operation in national airspace”

Forever Ready Productions, LLC video UASs are rotor craft weighing less than 55 pounds including payload. (The DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire class) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. UASs have an a uto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area

as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.

The very small nature of these UASs combined with t he safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operati ons of UASs to commence immediately.

Also due to the size of UASs and the areas and alti tudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk manag ement process. Given the clear direction given in Section 333 of the Reform Act, the author ity contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced sa fety, reduced emissions utilizing UASs

verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding lim itation on operations of ForeverReady Productions, LLC,



### 1. Flights will only occur in the day time hours, 

### 2. Flights will be operated in the line of sight of th e operator(PIC) and Observer,(VSO) 

### 3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by manufacturers recommendations, 

### 4. The UASs will weigh less than 55 lbs., 

### 5. Flights will be operated at 200 feet AGL or less. 

### 6. Crew will be at a minimum of operator(PIC) and an o bserver and/or camera operator(VSO), 

### 7. Operator and crew will remain in contact during the flight operation, 

### 8. The UASs operator will perform a check of the fligh t area and make certain of the safety of all persons in the area, 

### 9. Consent will be obtained from all persons with in t he video capabilities of the units to further reduce the chance of violating anyone's pri vacy. 

### 10. All required FAA clearances, will be obtained and d istances from airports strictly observed. 

### 11. All UASs will have the capability to return automat ically to the operator in a safe manner with the auto return function checked and wo rking. 

### 12. When operated in conjunction with fishing vessels i n the gulf, a chase boat will be assigned to operate the UASs at a safe distance fro m the main fishing boat. 

### 13. Flights will only operate in VFR conditions. 

### 14. UASs have a function on the control to tell operato r the distance away from the operator and its battery power remaining. 

### 15. Flight team will communicate by voice and the use o f two-way radio if the area is too great to hear voice from all team members. 

### 16. UASs will be used to video private outings and func tions, boating, jet skiing, kayaking, fishing trips in the gulf area and sporting events from a safe distance. 

### 17. When operating over or near water the UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium bat tery exposure to the water table.

14 CFR part 21Subpart H: Airworthiness Certificate 14 CFR 91.7(a}, 91.203(a)(l) Subpart H,entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a) (l). The size, weight and defined area of operations for Forever Ready Productions, LLC UASs flights permits exception from Part 21 because they meet an equivalent level of safety pur suant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airwo rthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Refo rm Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certifica tes in consideration of weight, size, speed,maneuverability and proximity to areas such a s airports and dense populations. Forever Ready Productions, LLC meets or exceeds each of the se elements

As of March 23, 2015 the FAA has stated that it wil l automatically grant a "blanket" COA for flights at or under 200 AGL to any UASs operator wi th a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and reg istrations at Forever Ready Productions, LLC operations center.

14CFR91.7 (a) prohibits the operation of an aircraf t without an airworthiness certificate. As no such certificate will be applicable in the form con templated by FAR's this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in A ircraft

14 CFR 91.9(b)(2) requires an aircraft flight manua l in the aircraft. As there are no pilots or passengers, and given the size of the UASs this reg ulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining such certifi cations and registrations at Forever Ready Productions, LLC operations center.

The FAA has previously issued exemptions to this re gulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,1 0602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes sa fe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitude s in certain conditions. Forever Ready Productions, LLC will only operate its UASs at or b elow 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for ha zards and minimizes the presence of any persons not essential for these operati ons. Fl i ghts will onl y be over pri vate property that the

owner has consented and all persons wi thi n thi s vi deo area al so give consent for thi s fil mi ng

. Compared to flight operati ons of conventional and tradi ti onal ai rcraft or rotorcraft wei ghi ng far more than 50 lbs

, operati ng below 500 AGL wi th fl ammabl e fuel UASs operati ons present a far smaller risk to the publ ic.

Approval of these 333 Exemptions allowing commercia l operations of small UASs in the service of aerial photography wilI greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photo graphy requires large aircraft with flammable fuel to fly in close proximity of populated areas a nd people in general. With the use of small UASs of 55 lbs. or less,batte ry operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Forever Ready Productions, LLC will give the people another avenue to express themselves and to have a video record to share with family and friends forever.

Granting Forever Ready Productions, LLC the above e xemption will allow for the expansion of UAS systems into the future for the sa fe conduct of free enterprise and the enjoyment of the masses.

Forever Ready Productions, LLC respectfully request s the FAA grant its exception without delay. The FAA has the authority to issue the exemp tion sought by Forever Ready Productions, LLC pursuant to the Federal Aviation Act, 85 P.L. 7 26 {1958) as amended {the ACT).

Respectfully submitted,

Scott W Ready Owner Forever Ready Productions, LLC

### INTERESTS OF THE PETITIONER

The objective is to expand a small video production business into Aerial Video and Photography Service to provide high quality imaging for a variety of co mmercial and public uses, specifically targeting:

- Wedding and Special Events coverage

- Local news coverage

- Video for Real Estate agents

- Coverage of Sporting Events

- Interviews of individuals

**UAS/AERIAL EQUIPMENT OF THE PETITIONER**

- DJI Phantom 2 Vision+

- DJI Phantom 3

- DJI Inspire 1

- DJI Inspire class UASs

Forever Ready Productions, LLC only utilizes safe a nd reliable UASs. DJI is an industry leader in smal l UAS production. DJI UASs are loaded with ground bre aking software enabling the user to set parameters which will not allow flight into control led airspace. Parameters can also be set to limit f light to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-t ime altitude and location information to the PIC vi a the linked monitor (smart phone/tablet devices)