February 26, 2016

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, 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 C.F.R. 21 Subpart H; 14 C.F.R 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7 (a), 91.119 (c), 91.121, 91.151 (a) (1), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) and (b)

De ar Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and the procedures
contained within 14 C.F.R. Part 11, I, Jason Lee, operator of an Unmanned Aircraft System ( sUAS ), hereby apply, on behalf of Vector Life LLC, for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of my SUAS , so long as all operations are conducted within and under the conditions outlined or as may be given by the Federal Aviation Administration (FAA ) as required in Section 333.

I, Jason Lee, am experienced in flying multi

- rotor helicopters as I use the DJI Phanto m 3 Professional, DJI Inspire Pro

, DJI Spreading Wings S1000 octocopter, and X8 Octocopter for recreational purposes at the present time

. In order to operate my Phantom 3 Professional, Inspire Pro

, S100 0 Spreading Wings and X8 Octocopter for use in aerial videography and photography sal es, real estate marketing , advertising, marketing, event promotions and closed

- set filming

. I, Jason Lee on be half of Vector Life LLC, would like to formally request exemptions from: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

If granted these exemption s , I, Jason Lee, will comply by the regulati ons and restrictions set by the FAA’s
grant.

I request these exemptions in order to provide a cheaper alternative for real estate agents and homeowners compared to video or photo captured by manned aircraft. Vector Life, LLC would like to also provide aer ial videography and photography to raise tourism to the Central Coast of California and benefit the marketing of the Pismo Beach Chamber of Commerce as well as San Luis Obispo County as hired. Special events would also be available for filming or photograp hy, providing a unique view for special events in the area such as weddings and city events. Public safety will be affected positively by getting the same quality of footage for clients as previously taken with helicopters, but without the use
of fuel bas ed manned aircraft, saving energy, less released pollutants, and less possibility for a
hazardous accident due to combustible fuel.Applicant:

Jason Lee
Owner
Vector Life LLC
695 Price Street
Suite 102 Pismo Beach, California 93449 jasonlee@vectorlife .com 805

- 295

- 6306

The requested exemption would permit the operation of a DJI Inspire Pro , DJI Phantom 3 Professional, DJI Spreading Wings S1000

, X8 1000 Octocopter SUAS only under controlled conditions in the NAS that
would be a) limited, b) controlled, c) predetermined and d) will provide safety improvements to the industry.

THE SUAS

1. DJI S1000 Octocopter

a. Dimensions: 41.14 in diagonal
b. Weight: 13 lbs

c. Max Speed: 20 m/s
d. Frequency Spectrum : 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controll er: DJI A2
2. DJI Inspire 1 Pro Quadcopter

a. Dimensions: 17.24in x 17.75 in x 11.85 in
b. Weight : 7.5 lbs

c. Maximum Speed: 18 m/s
d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI Inspire 1

3. DJI Phantom 3 Pro Quadcopter

a. D imensions: 23 in diagonal
b. Weight: 2.8 lbs

c. Max Speed: 16 m/s
d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI Phantom 3

4. X8 Octocopter

a. Dimensions: 41.14 in diagonal
b. Weight: 13 lbs

c. Max Speed: 20 m/s
d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI A2

Similar operations for the DJI Phantom 3 Professional have been granted for exemptions by the FAA such as Exemption No. 13958 (Strickland) and Exemption No. 1 3961 (M cCartney). Similar operations forthe DJI Inspire 1 have been granted for exemptions by the FAA such as Exemption No. 14118 (Gowdy)

and Exemption No. 13678 (Coffman) amongst more. The DJI Spreading Wings s1000 has also been given exemptions for simi lar operations as seen again in Exemption No. 13678 (Coffman) and Exemption No. 14224 (Caccamo)

. The sUAS consists of their unmanned aircraft and attached cameras.

The Inspire 1 Pro only differs from the Inspire 1 by having an upgradeable camera, dual pil ot operation and a 360 degree un obstructed view for your shots, thus not affecting safety negatively. Dual pilot operation in fact may make operation of the sUAS safer with two people in control of the copter rather than just one.

sUAS OPERATIONS

The d rone will be safely operated by operating t he sUAS only as described in their respective manuals.

Pre

- flight inspections would take place before every flight and will consist of the following:

1. Make sure flight plan is in line with local regulations for s UAS flight. 2. Check the environment for adverse weather, people or animals, hazardous objects, and magnetic interference. 3. Inspect the s UAS

- Install propeller guards

- Confirm that all bat teries are fully charged and free of damage. This includes
batteries for the s UAS , remote controller and mobile device.

- Inspect the propellers, gimbal, camera and remote controller for damage

A post

- flight inspection will also take place which includes l ooking over the s UAS after every f l ight to check for damage. The s UAS will be maintained and checked for safety in this way before and after every flight. It will be repaired properly through the manufacturer were it to be dysf unctional and logged in airc raft records that it underwent maintenance.

I, Jason Lee, am qualified to fly the drone with over 100 hours of experience flying remote controlled
mulit

- rotor helicopters. I have been flying and building multirotor aircraft since March 2012. I received a B.S. in Electrical Engineering from Cal Poly University. I have extensive knowledge of how to build, repair, & maintain an air worthy RC multi

- rotor helicopter. My experience building and flying multirotor RC helicopters ranges from small pocket size qua dcopters to large heavy lifters suitable for carrying payloads of 30 lbs. With this experience, I am able to make decisions ensuring the safest flight possible
for the UAV

. I have extensive knowledge of weather and how it affects RC flight and consider wea ther one of the most important factors when deciding the safety of the flight.

I have hosted two f ree DJI New Pilot Experience classes to help introduce multi rotor RC to the community. The New Pilot Experience not only covered the mechanical and software operations of the Phantom 3 but we focused a lot on flying safe in accordance with the safety training and guidelines from www.knowbeforeyoufly.org.

The s UAS will be used to capture aerial videography and photography for the use of sales , marketing,
advert ising, & promotions for the Central Coast. It would also be used upon hire for real estatemarketing, special event filming , advertising and closed

- set motion picture and television filming

. The

s UAS would not affect safety due to always being at the minimum distance of 500 f ee t from unparticipating persons and potentially hazardous objects such as vessels, vehicles, structures , magnetic interference and power lines etc. The sUAS will not fly within 500 feet of anyone’s property or person
without their express permission. During the pre

- flight check list the area will always be checked for people and animals before takeoff. These potential hazards will be avoided by utilizing the pre

- flight checklist and keeping the sUAS within line of sight.

The s UAS will not be flown in dangerous weather conditions such as: rain, snow or wind. It w ill be flown

at a minimum of 20 ft

. and a maximum of 400 ft. The s UAS will always be within a minimum of 500 feet below or less than 2,000 feet horizontally from clouds

.

T here are some built in s afety features for the DJI Phantom and Inspire s UAS that include: GPS Assisted Hover (a minimum of 12 satellites available at all times), a Vision Positioning System that assists in safe flights, the Return To Home feature allowing the s UAS to return home with the press of a button, and
the Inertial Measurement System keeps the s UAS stable

. The DJI Spreading Wings S1000 & X8 1000 ha ve an A2 flight controller which keeps it stable even in the case of losing a rotor.

Operations will take place over rural and private land in the state of California, mostly limited to the
Central Coast. Property will not be flown over without the consent of the owners. The s UAS will no t be operated within 5 miles of any airports without first advising them of estimated flight time and duration, elevation of flight and other need information.

The s UAS will only be operated within line of sight of the visual observer ( VO ) and pilot in command (P IC ) . This will be ensured by not flying the drone further than 1,000 feet from the operator and VO.

Exemptions Requested

An exemption from 61.23 (a) and (c) has been requested because the s UAS will not be carrying passengers therefore there is little reason the PIC should need a medical certific a te. A medical certificate wouldn’t be needed for the operation of a s UAS since it operates in controlled environments away from people and doesn’t carry passengers or the pilot. In this form of aircraft no one is at a large risk for needing medical attent ion the way one might on a civil aircraft such as a private or commercial flight.

An exemption from 61.101 (e) (4) and (5) , 61.113 (a), and 61.315 (a) has been r equested because while normally a commercial license would be needed to further a business o r to gain compensation, in this case getting a commercial license would be excessive as the s UAS does not carry property or passengers, instead only a n attached camera. Compensation and the furthering of a business isn’t done through risky transportation m eans, but instead through capturing images. It’s in fact safer to gain aerial images through the s UAS rather than a manned aircraft given the s UAS ’s small size and slow speed in comparison. A private license, recreational license or sport pilot certificate will already be a huge gain in safety as operating a manned aircraft is much more involved than a s UAS which would operate more similarly to a remote controlled helicopter than a civil aircraft . A recreational license or sport pilotcertificate is more than enough to ensure the s UAS is operated safely . S ince the s UAS isn’t carrying

passengers or property a recreational license should be in this case exempt from not being able to use the craft for business. The PIC will hold a private, recreation al or sport pilot certificate along with a valid
U.S. driver’s license.

An exemption from 91.7 (a) has been requested because a certificate of airworthiness is not applicable
as no certificate will be issued for the s UAS . Following requirements in the s U AS ’s respective operating
manuals and implementing pre and post flight checks however will give the same amount of safety as gaining a certificate of airworthiness.

An exemption from 91.119 (c) has been request ed because it would be unsafe for a s UAS to fly at the
same altitude as civil aircraft. The s UAS is much smaller and not capable of such altitudes. Section (d) of 91.119 allows for helicopters to operate at lower altitudes under specific conditions. An exemption for a

s UAS would act similarly. The s UAS will never operate higher than 400 feet above ground level as has
been the limit for other s UAS 333 exemptions such as Exemption No. 14003, 13910, 14005 and more. An equivalent level of safety will be reached as the s UAS will be operating at a safer al titude below 400 feet than it would at the approved altitude of civil aircraft.

An exemption from 91.121 has been requested because the s UAS will not have a barometric altimeter to set the “elevation of the departure airport or an appropriate altimeter setting available before departure.” An exemption would still allow for an equivalent level of safety as the s UAS is equipped with
GPS and uses the system to navigate safely. Altitude can be checked before and during flight with the

GPS.

An exemption from 91.151 (a) (1) has been requested because the section prohibits flight unless there is enough fuel to operate from departure point to take of f point with 30 minutes of fuel to spare during the day and 45 minutes of fuel to spare at night. The s UAS itself can only operate around 23 minutes on battery power. It is impossible to meet the amount of reserved fuel time currently set. An exemption would still allow for an equivalent level of safety as before every flight the s UAS battery will be checked

t o assure it is full y charged , as well as the battery on the remote and mobile device that acts as a screen. If any batteries are too low of power to successfully and safely land the s UAS back at its home point

, the flight will be cancelled. This procedure must take place before every flight. If the battery reserve
becomes less than 25% during a flight the s UAS must land. The size and speed of the s UAS also pose a much lesser risk than that of a civil aircraft not having a 30 minute or greater reserve of fu el.

An exemption from 91.405 (a) , 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) and (b) has been requested because the section only applies to aircraft with an airworthiness certificate which as explained earlier, the s UAS will not have. An equivalen t level of safety will be achieved with pre

- flight inspections before every flight. The operator will take care of needed maintenance by following the

s UAS operating manuals.Public Interest

While briefly mentioned earlier, granting these exemptions i s best for the public because it will allow for
small businesses to have better access to aerial photography and videography to prom ote and sell their own product and compete with larger businesses who could afford the high prices from the past. Aerial pho tography and videography can be done for much cheaper now when using a s UAS rather than a civil
aircraft.

Drone videography and photography benefits many industries including: construction, real estate, event planning, marketing, advertising, event promo tions and more.

Aerial photography and videography is also done at a safer capacity with drones as they are smaller in size, weigh less, and no one is on board the craft if something goes wrong. The s UAS doesn’t consume
flammable fuel allowing for safer landing and safer accidents were they to occur. Less pollutants are
releas ed into the atmosphere as well since the s UAS do not use fuel.

Summary for Federal Register

Pursuant to 14 C.F.R Part 11 Subpart A §11.81, a summary is provided for publication purposes: Jason

Lee seeks an exemption from the following limitations:

1) 61.23 (a) and (c) 2) 61.101 (e) (4) and (5) 3) 61.113 (a) 4) 61.315 (a) 5) 91.7 (a) 6) 91.119 (c) 7) 91.121 8) 91.151 (a) (1) 9) 91.405 (a)

1 0) 91.407 (a) (1) 11) 91.409 (a) (1) and (2) 12) 91.417 (a) and (b)

An exemption would allow for Vector Life, LLC to use drones to benefit both the private and public sector in the following industries:

- Real Estate

- Construction and L and development

- Eve nt Promotions

- Marketing- Advertising

- Aer ial Videography and P hotography

- Closed

- Set Filming for Motion Pictures and Television

We will comply with the following limitations should this exemption be granted:

1) Commercial operations will be limited to the a ircraft specifically mentioned in this document: DJI Phantom 3 Professional Quadcopter, DJI Inspire 1 Pro Quadcopter, DJI Spreading Wings 1000 Octocopter and X8 Octoctoper

. 2) The sUAS will not be flown at a speed exceeding 25 m/s. 3) The sUAS will be operated no higher than 400 feet above ground level. 4) The sUAS will be operated in the visual line of sight of the PIC at all times. 5) All operations will utilize a visual observer and the sUAS will be in his and the PIC’s line of sight
at all times. The visual obse rver will be within talking or radio distance of the PIC and will keep his duties the entire flight time. 6) The sUAS pilot will have a private, recreational, or sport pilot’s license and a valid U.S. driver’s
license or FAA airman medical certificate. 7) Operating documents will be available at all times the sUAS is operational and made available to the Administrator upon request. 8) The sUAS will not fly before the PIC goes through the pre

- flight check list. Post

- flight the sUAS will always be checked for d amage. 9) We will follow the sUAS manufacturer’s manual in regards to maintenance, inspection and life limit of the craft. The manual will be followed in all other aspects. 10) The sUAS will be operated during the day for safety precautions. 11) The sUAS will not operate within 5 miles of the geographic center of an airport without first requesting permission the nearest control tower of estimated flight time and duration, elevation of flight and other need information

. 12) The sUAS will not be operated less than 500 feet below or 2,000 feet horizontally from a cloud. 13) If the sUAS loses communication with GPS it will return home and land immediately. 14) A flight will be cancelled if hazards come to light. 15) The sUAS will not fly without sufficient battery power in the bat teries of itself, the remote and
the monitor. 16) The radio frequencies used by the sUAS will be FCC compliant. 17) The PIC of the sUAS will have required documents available when operating the sUAS and make
them available to the administrator and law enforcemen t upon request. 18) The sUAS will be clear of manned aircraft and give them the right away. 19) The sUAS will not be operated in heavily populated areas. 20) The sUAS will be operated at a minimum of 500 feet from nonparticipating persons, and property or vessels w hose owners did not give permission to be flown over. 21) All flights will operate only under Visual Meteorological Conditions. 22) A Motion Picture and Television Operations Manual will be followed for all closed

- set motion picture and televis ion filming.Pl ease feel free to contact me if you need additional information,

Thank you for your time and consideration,

Jason Lee
Vector Life LLC

695 Price Street
Suite 102 Pismo Beach, California 93449 jasonlee@vectorlife.com

805

- 295

- 6306