To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R Part 11, Whitewater Imagery Inc. is a new and developing filming and photography company and operator of a small (UAS) equipped f or photos and videos, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operations of its UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be es tablished by the FAA and required by Section 333.

Purpose of the proposed flight will be to provide:

• Photos and videos of real estate listing offered for rental and sale.

• Photos and videos used to promote tourism in the areas resulted in
potent ial tax receipts for Local, States and US Government.

• Photos promoting land for sale.

• Golf Course Photography.

• Cinematography.

• Monitor Crops.

• Surveys.

• Nature Photography.

• Photos and videos taken with UASs will be pr omoted on company’s

websites

, Facebook, Instagram and twitter. The name and address of the Applicant is: Whitewater Imagery

. Attn: David Coppola : 845

- 656

- 1777

Email: whitewaterimagery@gmail.com Address : 19 Leo Ct. Poughquag

N.Y. 12570

. Whitewater Imagery Inc. intends to service the needs of aerial filming and photography for the purposes of movie making, advertising and marketing in a variety of industries. Traditional methods of aerial filming and pho tography are handled by full sized, fixed and rotor wing aircraft which are no longer competitive when compared to the low acquisition and operating costs of small unmanned aircraft systems.These cost savings can be transferred to the advertiser then ulti mately to the consumer to promote competitiveness in the market place. Full sized aircraft have a greater environmental impact. They are significantly louder to operate than small, fully electric unmanned aircraft systems and carry a much larger carbon “fo otprint" adding to the growing concern of the emissions of greenhouse gases. Being all electric is beneficial in that it is significantly quieter and less likely to disrupt the peace of the surrounding flight operations area. Full sized aircraft carry

flam mable fuels and flight crew and/or passengers. There is a great deal of danger imposed to the flight crew and/or passengers and to those on the ground in the event of an emergency with regard to full size aircraft. This danger is considerably less in compa rison with the UAS due to its small size, maximum forward speed and lack of flammable fuels. Because Whitewater Imagery Inc. will have a public presence for commercial UAS aerial filming and photography, we will be available and willing to assist in disast er relief. There is no threat to National Security due to the Transportation Security Administration security screening of certificated airmen. The PIC is U.S. Citizen with zero criminal back ground and zero FAA violations and is greatly concerned

in ensur ing the public maintains their right to privacy. We believe that because of advancing technologies, small unmanned aircraft systems are much less expensive to acquire, easier to operate, and less demanding to maintain when compared to full size aircraft. U AS aerial services, such as filming, surveying, inspection and surveillance will undoubtedly promote public interest. Also the DJI Phantom 3 is sophisticated equipment with a built in program that does not even allow the drone to operate within 15 miles o f the white house are other high security areas.

Pilot In Command (PIC)

Name: David Coppola FAA Certificate #: FA3E933YYL

Ø Prior to any UAS flight, the PIC shall be trained in all aspects of flight operations. Training will include, but is not limite d to; Personal Computer Flight Simulation that is similar to the flight characteristics and control of the UAS to be used; actual flight training with the UAS tobe used in a designated flight area.

Ø Prior to any commercial flight operations, the PIC shall have accrued at least 25 hours of documented flight time with the UAS being operated by Whitewater Imagery Inc.

Ø Prior to any commercial flight operations, demonstration of complete control of the UAS shall be maintained. Proficiency flights

sh all include all normal flight maneuvers such as takeoff; a figure "8" coordinated turn flight pattern; and landings.

Ø T he PIC shall not participate in any flight operations, whether it be proficiency flights or revenue generating flights, if the blood alcohol concentration (BAC) level is 0.04% or higher, within 8 hours of having consumed any alcohol, while under the influence of alcohol, while under the influence of illegal, prescribed or over the counter drugs that would impair the ability to safely operate the UAS as prescribed in 14 CFR Part

91.17.

Ø The PIC shall not participate in any phone calls, phone conversations or operation of a two

- way radio during flight operations. All proposed flight paths and flight operations will be discussed by Whitewater Imagery Inc. and the customer prior to any fl ights in order to avoid unnecessary distractions. Every effort shall be made to prevent

non

- essential personnel from interfering with the PIC in any way during flight operations.

Ø All applicable licenses, certificates, permits, authorizations,

waiver s, exemption letters, flight and maintenance logbooks, personal identifications, and this Operations Manuals shall be made available to any law enforcing, State or National Government Entity at any) Record keeping

Ø Training qualifications and record keeping are maintained and tracked for the pilot in command and visual observer. The PIC is responsible for the management of all training, maintenance and flight

records.Ø Maintenance will only be conducted by an authorized DJI represented who i s certified by DJI to maintain a DJI phantom 3. Records will include date, time, specific detail of work done and name and or badge number of person who conducted the maintenance. Maintenance records will be kept for 7 years. Operational and

Maintenance re cords may be made available for inspection by the

Federal Aviation Administration. The UAS & Flight The UAS is a 3 lbs battery operated quadcopter (four motors, four blades) call the DJI Phantom 3 Professional, which consist of: 4k UHD video recording with fully stabilized 3

- axis gimbal; Vision Positioning system allows stable flight.

Ø Flight battery and rechargeable remote controller.

Ø DJI Pilot app for IOS and Android allows live viewing and complete camera control.

Ø The Phantom 3 Professional carries a fully stabilized 3

- axis 4k UHD video camera for smooth, crisp videos and still photos.

Ø To allow you to see what the drone sees, DJI has engineered a new generation of their Lightbridge technology that allows 720p HD digital streaming of live video directly from the drone.

Ø Includes GPS navigation with auto takeoffs and auto landings, intelligent high power flight battery, a built

- in safety database of no fly zones, and a powerful mobile app for your iOS or Android device.

Ø GPS Assisted flight

- Allows quadcopter to hover when no

command are be ing sent

- This is a nice feature in case the PIC needs to "regroup" during flight.

Ø Non

- GPS Modes

- If GPS signals are lost, aircraft goes into a mode that monitors and hold altitude and provides control assistance to help keep aircraft stable and und er total control of the PIC.

Ø LED Status Lights on Aircraft, along with warning system equipped on the pilot app which allows the PIC to always have full

situation awareness on his aircraft. Note: DJI has locked the Phantomfrom being able to even s tart the motor if you live within a 15 mile

radius of the White House. (The DJI Phantom 3 manuals will be attached to this packet) The UAS also have two bright gold bands in front of the quadcopter, these are used for orientation and location of

aircraft from line of site. MAX. Ascent Speed: 5m/s MAX. Descent Speed: 3m/s MAX. Flight Altitude 6000m MAX. Flight time approximately 23 minutes GPS: GPS/GLONASS

The powerful Remote Controller allows you to pilot and maneuver the

Phantom 3 Professional at dist ances over 6,000 feet away, while putting selected camera controls. Built into the Remote control is a rechargeable LIPo battery and DJI Lightbridge, which when paired with a compatible mobile device gives live HD view from the Phantom Camera.

Operating F requency: 2.400 GHz

- 2.483 GHz Max. Transmission Distance: 2 km Operating Temperature Range: 0c

- 40c Transmit Power: FCC: 20 dbm; CE: 16 dbm Charger: Voltage 17.4V; Rated Power 100W

The UAS will be operated by a Pilot in Command (PIC) with the following

res trictions:

Ø All operations will occur in Class G airspace at no more than 400' AGL. The vast majority of flights will be well below this limit at an average of 200' AGL to accomplish the best photographs and videos.

Ø Any required permits will be obtained from local and state government before flights.

Ø The Aircraft will not operate directly above human beings at any

time or within 150 feet of human beings.

Ø Maximum flight time will be 18 minutes. Battery allows 23 minutes of flight t ime. Batteries are inspected and always fully charged

before use.

Ø The Aircraft will not operate within 5 miles of an airport/heliport without prior approval from said airport/heliport.

Ø All operations will be during the daytime and in ideal weather

conditions of less than 15 mph winds and clear skies.Ø Aircraft will remain in visual line of site at all times not to exceed

1/4 miles from PIC.

Ø Visual observer will serve as additional eyes on the aircraft and be

within voice reac h to communicate with PIC

Ø Aircraft will not fly in the area of any full scale aircraft and if a full

scale aircraft comes into airspace during the aircraft's flight, it will be landed immediately to allow right of way to full scale aircraft.

Ø At any time Aircraft is being flown, signs will be posted in least three (3) locations, warning of UAS operations are being conducted and to stay at 200' away at all times of landing and takeoff areas.

Ø UAS will never be used as an invasion of p rivacy and only be used for purposes listed above.

Ø The UAS will never be flown near, in or over stadiums; or over large gathering of persons.

Ø The equipment is not inexpensive and I take general public and aviation safety seriously. I have developed pre

- flight plans, and maintenance plan to make sure the aircraft is always in safe flying

condition.

REASONS FOR EXEMPTIONS

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal Aviation Regulations from:

14 C.F.R. Part s 21, 45.29, 45.23:

The aircraft has no area to display numbers or letters that are at least 2” in size. To my Knowledge there are no registration systems for UAS. We will place in the largest letters “Whitewater Imagery Inc.” on the top of the

aircraft.

14 C.F.R. 91.7:To my knowledge there are no aircraft airworthiness certificates for UAS. We will before each flight run through the enclosed pre

- flight checklist to ensure

airworthiness.

14 C.F.R 91.9(b):

There is no cockpit to include said manual. O perating manual will be kept

with PIC.

14 C.F.R. 91.103:

Since there will not be a FAA approved quadcopter manual to be provided we will need to be exempt. We will again follow our enclosed pre

- flight checklist to ensure safety and airworthiness.

14 C.F .R. 91.109:

UAS are controlled by transmitter and do not have the capability for dual controls. It is our understanding there have been other aircraft approved

without dual controls.

14 C.F.R. 119:

Since flights will never be above 400’ AGL and usually around 200’ AGL, we requested an exemption as the altitude cited in 14 CFR 91.119 would cause us

to exceed said 400’ AGL.

14 C.F.R.91.121:

UAS does not have a traditional altimeter. The DJI Phantom 3 Professional uses sophisticated technology which enabl es precise GPS coordinates that gives real time positioning including altitudes and speeds all displayed on an Iphone or Ipad.

14 C.F.R. 91.51:

The UAS does not use traditional fuel but battery power. The battery provides for up to 25 minutes of flight. Battery power levels will be monitored using an apple application which gives the PIC the capability to enable the return home feature telling the UAS to return home and land. No flight will last longer than 18 minutes as an extra safety net. The quadcopte r is also equipped withpropeller guards to help p revent injury to any persons, animals , power lines,

etc as well.

All batteries are only used if freshly charged, all batteries are visually inspected and volt tested before each flight.

14 C.F.R. 91.203:

There is no cock pit to include said certificate or registration documents. Any certificates, exemptions or registration documents will be with the PIC on the ground level.

14 C.F.R. 91.405, 91.407, 91.409, 91.47:

As there are no airworthiness inspections available there fore we request an exemption. Again we will perform pre

- flight checklists to ensure safety. If our

pre

- flight checklist does not pass, we will abort flight. Any items of concern will promptly be repaired using similar components and records will be kept

th rough maintenance records.

We are prepared to modify or amend any part of this petition for exemption to meet or exceed concerns of safety; we do look forward to working with the FAA to provide a great service to our community and profession in a safe

man ner.

Sincerely,

David Coppola

President

Whitewater Imagery Inc.