### Business Photos America Inc. 202 Mustang Court Gambrills, MD 21054 September 27, 2015

US Department Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington, DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the F AA Modernization and Reform Actof 2012(the reform a ct) and CFR Part 11, Business Photos America Inc. (BPA), owner and operator of S mall Unmanned Aircraft Systems (UASs) for aerial mapping, aerial photo graphy and video for the real e state industry, agriculture industry, construction industry, s mall businesses, television and special events requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that Busines s Photos America Inc. may operate UASs commercially in airspace regulated by the FAA as long as such o perations are conducted within and under the conditions outlined herein or as maybe established bythe FAA as required by Section 333. An exception is being requested b ecause Business Photos America Inc. can provide a level of safety this is equal to those provided by e xisting rules, and the request i s in the public interest. The FAA’s authority to issue exemptions from operatin g rules, and the Secretary’s a uthority granted by Section 333 of P.L. 112‐95, Special Rules for Certain Unmanned Aircraft Systems, pr ovide an opportunity to authorize certain UAS operations in the Na tional Airspace System (NAS) pr ior to implementation of the UAS rule. This incremental step and oppo rtunity will allow BUSINESS PHOTO S AMERICA INC.to safely and legally enter into the NAS. All operatio ns will be performed with the p ublic’s safety and right to privacy safeguarded at all times. As described below, the requested exception would permit the op eration of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions in airspace that is limited, predetermined, subject to controlled access, and would provide safety enhancem ents to the already safe operation of those aircraft of similar size, weight, speed and operating cap ability that have been granted entry into the NAS via the rules in Academyof Model Aeronautics (AMA) Nat ional Safety Code. Business Photos America Inc. UASs are rotorcraft weighing less than 55 pounds including payload specifically the DJI Inspire 1 P ro Quad Copters, DJI Vision Pro Quad Copters, and the DJI 2 Vision+ Quad Copters. They operate at speeds less than 50 knot s and have the capability to hover and move in the vertical and horizontal plane si multaneously. They also have an auto return to launch point whenbattery power is under 25%. The UAS will operate within the lin e of sight with in a protected flight area as described below and at 400 feet AGL or less with an observerlocated close at hand as to make voice communication possible. These ope rations will not create a haza rd to users of the nation airspace, public nor the environment.

Business Photos America Inc. respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing i t 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), 91.40 9(a)&(b). Business Photos America Inc. submits this application in accord ance with the Reform Act 112 P.L. 95 331‐334, seeking relief from any c urrently applicable FAR’S ope rating to prevent Business Photos America Inc. future commercial use of small UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such i ntegration of civil unmanned aircraft into our national airspace syste m as it is in the public’s inte rest to do so. Business Photos America Inc. UASs meet the definition of “sma ll unmanned aircraft” as define d in Section 331 and therefor the integration of these UASs are ex pressly contemplated by the Reform Act. Business Photos America Inc. would like to operate its light w eight UASs prior to the time p eriod by which the Reform Act requires the FAA to promulgate rules go verning such aircraft.

The Reform Act directs the Secre tary of Transportation to consi der whether certain unmanned aircraft systems may operate safely in na tional airspace before completi on of the rule making required under Section 332 of the reform Act. In making this determination, th e Secretary of Transportation is required to determine which UASs do create a hazard to users of the nati onal airspace system or the public or pose a threat to national security in light of the following:

 The UASs size, speed, weight and operational capability

 Operation of the UASs in close p roximity to airports and popula ted areas

 Operation of the UASs within vis ual line of sight of the operat or Reform Act 333(a). If the secretary determines that such vehicl es “may operate safely in National Airspace System, the secretary s hall establish requirements forthe safe operation in national airspace. Business Photos America Inc. UASs are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots and have the capability to operate in the ve rtical and horizontal plane simultaneously. The UASs will operate only within the line of sight of the oper ator within a protected flight area and at 400 feet AGL or less. These will no t present a hazard to the na tional airspace nor the public. The very small nature of these UASs combined with the safe guar ds presented below, will allow for the safe operation greater than thatenvisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs t o commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception pres ents no national security issues and absolutely minimal safety concer ns which have been mitigated th rough our rigorous risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in theFederal Aviation Act, as amended, the strong equivalent level o f enhanced safety, reduced emissions utilizing UASs verses traditiona l aircraft as well as the econo mic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public’s inte rest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitation on o perations of Business Photos America Inc., 1. Flights will only occur in the day time hours, 2. Flights will be operated in th e line of sight of the operato r (PIC) and Observer, (VSO) 3. Flights will be terminated at any time weather and wind dete riorate to “unsafe for flight” by manufacturers recommendations, 4. The UASs will weigh less than 55 lbs., 5. Flights will be operated at 400 feet AGL or less. 6. Crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO), 7. Operator and crew will remain in contact during the flight o peration, 8. The UASs operator will perfor m a check of the flight area an d make certain of the safety of all persons in the area, 9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violati ng anyone’s privacy. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capab ility to return automatically t o the operator in a sa fe manner with the auto return function checked and working. 12. Flights will only operate in VFR conditions. 13. UASs have a function on the control to tell operator the di stance away from the operator and its battery power remaining. 14. Flight team will communicate b y voice and the use of two‐wa y radio if the area is too big to hear voice from all team members. 15. UASs will be used to video private outings and functions, b oating, kayaking and sporting events from a safe distance. 16. When operating over or near water the UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7 (a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requ irements for procurement of necessary certificates in rela tion to FAR 91.203(a)(1). The size, weight and defined area of operations BusinessPhotos America Inc. UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate require ment under both the Act (49 US C 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs f rom airworthiness certificates in consideration of weight, size, s peed, maneuverability and proxi mity to areas such as airports and dense populations. Business Photos America Inc. meets or exceeds each of these elements. As of March 23, 2015 the FAA has stated that it will automatica lly grant a “blanket” COA for flights at or under 200 AGL to any UASs operatorwith a section 333 exemption

. 14 CFR 91.203(a&b) provides for carrying of civil aircraft cert ifications and registrations. These are inapplicable for the same reason s stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Business P hotos America Inc. operations center. 14CFR91.7 (a) prohibits the operat ion of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’ s this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 91.9(b)(2) requires an aircraft flight manual in the air craft. As there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations a t Business Photos Ameri ca Inc. operations center. The FAA has previously issued exe mptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 a nd 32827.

14 CFR 91.119 Minimum safe altit udes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at low er altitudes in certain condit ions. Business Photos America Inc. will only operate its UASs at or be low 400AGL. They will be operated on a well‐defined AOR that has been carefully reviewed for hazards a nd minimizes the presence of an y persons not essential for these operations. Flights will only be over private property with the owner’s permission and with all persons within this video area also giving their consent for this filmi ng. Compared to flight operations of conventional and traditional airc raft or rotorcraft weighing fa r more than 50 lbs., operating below 500 AGL with flammable fuel, UASs operations present a far smaller risk to the public. Approval of these 333 Exemptions allowing commercial operationsof small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography r equires large aircraft with fla mmable fuel to fly in close proximity of populated areas and people in ge neral. With the use of small UA Ss of 55 lbs. or less, battery operated and fling below 400 feetAGL the risk of injury of people on th e ground or the crew has been greatly reduced and almost eliminated. Granting Business Photos America Inc. the above exemption will allow for the expans ion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses. Business Photos America Inc. respectfully requests the FAA gran t its exception without delay. The FAA has the authority to issue the exemption sought by Business Pho tos America Inc. pursuant to the Federal Aviation Act, 85 P.L. 726 (1 958) as amended (the ACT).Thank you for your consideration. Sincerely,

Frank Clark

Business Photos America Inc. 202 Mustang Court Gambrills, Maryland 21054 (410) 320‐2352 Frank@BusinessPhotosAmerica.com