Sr£sfiepp 

June zznd, 2015 

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Ave., SW 

Washington, DC 20591 

Dear Sir or Madam: 

'Enterprises L.LC 

Attached please find Shepp Enterprises LLC ("SE") request for an exemption from 

the listed Federal Aviation Regulations to allow commercial operation of its Small 

Unmanned Aircraft Systems ("sUASs") for imaging real-estate, film productions, 

safety matters, along with the monitoring of secured and controlled environments. 

This exemption request is for the use of Da-Jiang Innovations (DJI) UASs, a China 

based company. 

Also attached to this letter is both UAS Flight Manuals ("Manual"), which outlines 

the operation requirements, limitations, and technical specifications for our DJI 

systems. SE has reviewed these manuals and has found it to be acceptable for sUAS 

operations on its projects sights and film sets. 

Thank you for your time and consideration. Please contact me if you have any 

question. 

Respectfully, 

Shepp 

~~zEnterprises 

Y LLC 

CEO/President 
SCEsfiepp 

june 10, 2015 

U.S Department of Transportation 

Federal Aviation Administration 

800 Independence Ave., SW 

Washington, DC 20591 

P.nterprises ££C 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a) & (b); 91.7(a); 91.9 (b)(2); 91.103(b); 91.109; 91.121; 91.151(a); 

91.204(a) & (b); 91.405(a) (1); 91.409(a) (2); 91.417(a) & (b). 

Dear Sir or Madam: 

Pursuant to Sections 333 of the FAA Modernization and Reform Act of 2012 

(the Reform Act and 14 C.F.R. Part 11, Shepp Enterprises LLC (SE), a film production 

company, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operations of its Small Unmanned 

Aircraft Systems ("sUA$") for aerial cinematographaphy for film and commercial 

productions, aerial imaging for commercial and residential real estate use, aerial 

imaging for safety and monitoring of secured and controlled environments, aerial 

imaging for search and rescue as well as assisting local law enforcement and rescue 

crews, so long as such operations are conducted within and under the conditions 

outlined herein or as may established by the FAA as required by Section 333. 

As detailed in this document and the attached Flight Manual, the requested 

exemption would permit the operations sUA$ under controlled conditions in 

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would 

provide safety enhancements to the already best practices safety protocols followed 

by SEat each and every film set or job location. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation's (the FAA 

Administrator's) responsibilities to " ... establish requirements for the safe operation 

of such aircraft systems in the national airspace system." Section 333 (c) of the 

Reform Act. 

The name and address of the applicant is: 

Shepp Enterprises LLC (UpTop Imaging & Secured Surroundings) 

Bradley Shepherd 

PH: 253-495-2223 

Email: bradley@uptopimaging.com I bradley@securedsurroundings.com 

Address: 9434 200th St E, Graham WA, 98338 
SCEsfiepp 'Enterprises LLC 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151 (a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 407 (a) (2) 

14 C.F.R. 417 (a) & (b) 

1. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue 

exemptions. This statutory authority includes exemptions civil aircraft, as the term 

is defined under §40101 of the Act, including sUASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsections (a) or (b) of this section or any sections 

44702-44716 of this title if the Administrator finds the exemption in the public 

interest. 49 U.S.C §44701 (f). See also 49 U.S.C. §44711 (a); U.S.C. §44704; 14 C.F.R. 

§91.203 (a) (1). 

Section 333 (b) or the Reform Act assists the Secretary in determining 

whether sUASs may operate in the National Airspace System (NAS) without creating 

a hazard to the use, the public, or a threat to national security. In making this 

determination, the Secretary must consider: 

• The sUASs size, weight, speed, and operational capability 

• Whether the sUAS operates within the visual line of sight of the 

operator 

• Whether the sUAS operates outside highly populated areas and away 

from close proximity to airports 
SCEsfiepp 'Enterprises ££C 

SE's first sUAS multirotor vehicle weighs 3-pounds, including its fixed highperformance camera (OJI Phantom 3). SE's second sUAS multirotor vehicle weighs 

6.5-pounds, with a detachable high-performance camera (OJ I Inspire 1). SE's third 

multirotor vehicle weighs 10 pounds, with a 21-pound max payload (OJI S1000+ ). 

SE's fourth multi rotor vehicle weighs 5.5-pounds, with a 7.5-pound max payload 

(OJI Matrice 100). They operate under normal conditions at a speed of no more than 

SO knots, with the capability to hover, move on a vertical and horizontal plane 

simultaneously. The sUASs will operate only in the pilots visual line of site at all 

times and will operate only within the sterile area described in the all OJI manuals, 

attached as Exhibit 1 (hereinafter "the Manuals"). Such Operations will insure that 

the sUAS will"not create a hazard to users or the national airspace system or the 

public." Reform Act Section 333 (b). 

Given the small size of the sUAS involved and the restricted and sterile 

environment within which they will operate, our application falls squarely within 

the zone of safety (an equivalent level of safety) in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations of sUASs to commence 

immediately. Also due to the small size of the sUASs and the low altitudes and 

restricted areas in which our sUASs will operate, approval of the applications 

presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety, the grant of the requested exemptions is in the public 

interest. Accordingly, SE respectfully requests that the FAA grant requested 

exemption without delay. 

2. Public Interest 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary 

of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the NAS before completion of the rulemaking required under 

Section 333 of the Reform Act. By granting an exemption, the FAA will fulfill 

Congress's intent of allowing UAS to operate with significant safety precautions in 

low risk environments. 
SCEsfiepp 'Enterprises L£C 

The use of sUASs to assist in aerial imaging in search and rescue can 

significantly reduce risk to public safety workers as well as civilians. sUASs can 

inspect, photograph, and collect data in and around hard to get or hazardous areas 

that otherwise would require personal to put themselves in danger to gather the 

information. 

In addition, having a knowledgeable and experienced crew and personnel 

working with the sUASs on film productions sets as well as capturing images for real 

estate will decrease the amount of inexperienced pilots by giving the clients a safer 

option to go with. 

Additionally, sUASs could replace the use of helicopters and small aircraft to 

monitor sites and capture cinematography. The sUASs we propose to fly in these 

applications range from payloads reaching as much as 45-pounds, with total 

payload and carry no combustible material on board, as opposed to the much larger 

conventionally powered small aircraft. Shifting to sUASs from helicopters presents a 

marked safety increased for our film crews and the public. 

Lastly, sUASs reduce the environmental impact by dramatically decreasing 

the energy used for aerial imaging, data collection, and aerial cinematography for 

film productions. Our sUASs use rechargeable lithium ion batteries, as opposed to 

fossil fuels burned in operation of small aircraft that are many hundreds of times 

heavier. 

3. EQUIVALENT LEVEL OF SAFETY 

SE proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provided for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe protocols followed on film 

production sites, imaging areas, and surveying operations conducted with 

helicopters and other conventional aircraft. 
SCEsfiepp 

fBnterprises ££C 

SE will be bound by the following limitations when conduction its sUAS 

operations under a FAA issued exemption: 

1. The sUASs will never exceed 48 pounds at any given time. 

2. Flights will be operated within visual line of sight of the pilot. 

3. Maximum total flight time for each operation flight will be 20 minutes. 

The sUASs calculates battery reserve in real time and will return to its 

home within 20% battery power reserve, should that occure prior to 

the 20 minute limit 

4. Flights will be operated at an altitude of 200 feet AGL, never 

exceeding the 400 feet AGL. 

5. Crew for the operations will consist of the sUAS pilot who will keep 

the sUAS within his/her visual sight at all times. 

6. The sUAS pilot will be trained in flight, operations, and safety 

procedures as detailed in the Flight Manuals and SE's requirements. 

7. The sUAS will operate within a confined "Sterile Area" and will always 

have an established "Security Parameter" for the flight operations 

area. 

8. A briefing will be conducted in regards to the planned sUAS 

operations prior to each day's productions activities. 

9. All onsite personnel will consent to the sUAS flyover on site by waiver, 

and the operator will obtain additional verbal or written consent of all 

persons. 

10. The pilot will have been trained in operations of sUASs generally and 

receive up-to-date information on particular sUASs planned to be 

operated. 

11. Written and/or oral permission from the relevant property holders 

will be obtained. 

12. All required permissions and permits will be obtained for territorial, 

state, county and/or city jurisdictions, to include local law 

enforcement, fire or other appropriate governmental agencies. 

13. If the sUAS loses communications or loses its GPS signal, it will have 

the capability to return to a pre-determined "home" point with in the 

"Security Parameter and land. 

14. If the sUAS will have the capability to abort a flight in case 

unpredicted obstacles or emergencies. 
4. DESCRIPTION OF SPECIFIC REGULATIONS 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 

§91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, established 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 SE, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 21 and Section 333 of the 

Reform Act The Federal Aviation Act (49 U.S.C. §44701 (t)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

air worthiness certificate, upon consideration of the size, weight, speed, operation 

capability, and proximity to airports and populated areas or the particular sUAS. All 

our sUASs will be operated at low speed in a controlled environment, at least five 

miles from an airport and more than three miles from any densely populated area. 

An analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least safe (or safer) than a conventional fixed andjor rotary 

winged aircrafts operating with an airworthiness certificate without the restrictions 

and conditions proposed. 

The sUASs to be operated hereunder are less than 48-pounds fully loaded, 

carries neither a pilot nor passenger, carries no explosive material or flammable 

liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by the 

operator, pursuant to the Manual's requirements, to provide cinematography and 

photography for are of operations as is currently done on active film production sets 

and more. The local law enforcement as well as the FAA will have advance notice of 

all operations. 

These safety enhancements, which already apply to civil aircraft operated in 

connection with film productions, 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, Subpart H. Lastly, applications of these 

same criteria demonstrates that there is no credible threat to nation security posed 

by the sUASs, due to their size, speed of operation, location of operation, lack of 

explosive materials or flammable liquids fuels, and ability to carry and external load 

no greater than 20-pounds. 
SCEsfiepp 

f£ntetprises ££C 

14 C.F.R. 45.23 (b): Marking of Aircraft 

This regulation requires certain experimental, provisionally certificated 

aircraft, or light-sport category aircraft to be marked with letters between 2 inches 

and 6 inches high "limited," "restricted," "light-sport," "experimental," or 

"provisional," near each entrance to a cabin cockpit or pilot station. 

Even though the sUASs will have no airworthiness certificate, an exemption 

may be needed, as the sUAS will have no entrance to the cabin, cockpit, or pilot 

station on which the word "Experimental" can be placed. Given the size of a sUAS, 

two 2-inch letters 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 sUAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the sUAS will see the identification of the sUAS as "Experimental". The FAA has 

issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 

10167, and 10167 A. 

14 C.F.R. 61.113 (a) & (b): Private pilot privileges and limitations: Pilot 

in Command 

Sections 61.113 (a) limit private pilots to non-commercial operations. 

Because the sUAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety operations by requiring the pilot operating the 

aircraft to have completed a sUAS flight-training course of 100hours before flying a 

sUAS as recommended by the Manual. Unlike a conventional aircraft that carries the 

pilot and passengers, the sUAS is remotely controlled with no living thing or cargo 

on board. The area of operation is controlled, restricted environment. All flights are 

planned and coordinated in advanced. The risks associated with the operation of the 

sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a pilot who has met the minimum requirements recommended in 

the manual exceeds the present level of safety achieved by 14 C.F.R. §61.113 

(a)&(b). 
SCEsfiepp 'Enterprises ££C 

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 the airworthy condition. As there will be no airworthiness certificates issued 

for the aircraft, should this exemption be granted, no FAA regulatory standard will 

exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety checklists 

prior to each flight, as set forth in Section Band Section G and equivalent level of 

safety will be provided. 

14 C.F.R. 91.9 (b) (2): Civil aircraft flight manual, marking, and placard 

requirements 

The sUAS, given its size and configurations has no ability or place to carry 

such a flight manual on the aircraft, not only because 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 sUAS will have immediate 

access. The FAA has issued the following exemptions to the regulations: Exemption 

Nos.8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,32827, 

and 10700. 

14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command to take certain actions before 

flight to ensure the safety of flight. An exemption is needed from this requirement, 

as the pilot will take separate preflight actions, including checking for weather 

conditions, checking flight battery requirements, checking takeoff and landing 

distances, and all other actions that are required in the Pre-flight Checklist in the 

Manual. These actions will provide an equivalent level of safety. 

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 instructions unless that aircraft 

has fully functioning dual controls. 
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By design, sUASs and remotely piloted aircrafts 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 communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. See 

Exemptions Nos. 5778K & 9862A. The equivalent level of safety provided by the fact 

that neither a pilot nor passengers will be carried in the aircraft, the ability to 

control the sUAS via radio signals from the controller, and by the size and spped 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 (b) allows helicopters to be operated at less than minimums 

prescribed, provided the person operating the helicopter complies with any route or 

altitudes of 200-feet AGL, so an exemption may be needed to allow such operations. 

The sUAS will never operate at altitude higher than 400-feet AGL and will be in 

restricted area with security parameter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of 

the sUASs, as well as the location where it is operated. No flight will be taken 

without the permission of the property owner and local officials. Because if the 

advance notices to the property owner and any onsite personnel, 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 52 

pounds proposed herein and carrying flammable fuel, any risk associated with our 

operations is far less than those presently presented with helicopters and other 

conventional aircrafts operating at or below 500-feet AGL in the film industry. In 

addition, the low altitude operations of the sUAS will ensure separation between 

these sUAS operations along with 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 is set" ... to the elevation of the 

departure airport or an appropriate altimeter setting available before departure." As 

the sUASs may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 
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14 C.F.R. 91.151 (a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR 

conditions. Our sUASs are limited to operations in sterile and controlled 

environments and has a limited range and flight time, which required and 

exemption from 14 C.F.R. 91.151 (a). 

The battery powering the sUAS provides approximately 35 minutes of 

powered flight. To meet the 30-minute reserve requirement in 14 C.F.R. §91.151, 

sUAS flights would be limited to approximately 5 minutes in length. Given the 

limitations on the sUASs proposed flight area and location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or 

night VFR conditions is reasonable. 

SE believes that an exemption from 14 C.F.R. §91.151 (a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151(a)). Operation the 

sUAS 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 

or reserve fuel, does not engender the type of risks that Section 91.151 (a) was 

intended to alleviate, given the size and speed of the sUAS. Additionally, limiting 

sUAS flight to 10 minutes would greatly reduce the utility for which the exemption 

will be granted. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, 

or enough battery reserve to ensure that the sUAS lands at the grounding station 

with at least 20% of battery power (as determined by the on board monitoring 

system and the pilot)., whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operating area. 

Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745,10673, and 10808. 
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14 C.F.R. 91.203 (a) & (b): Carrying civil aircraft certification and 

registration 

The regulation provides in 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 or crew. 

The sUAS fully loaded will never surpass 45 pounds and is operated without 

an on board pilot. Therefore there is no ability or place to carry certification and 

registration documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at 

the ground flight control point where the pilot operating the sUAS will have 

immediate access to them, to the extent they are applicable to the sUAS. The FAA 

has issued numerous exemptions to this regulation. A representative sample of 

these exemptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797 A, 

9816A, and 10700. 

14 C.F.R. 91.405 (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 other shall inspect or 

maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 applies only to aircrafts with an 

airworthiness certificate, these sections will not apply to SE. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating 

handbook as referenced in the Manual. An equivalent level of safety will be achieved 

because these sUASs are very limited in size and will carry a small payload along 

with operate only in restricted areas of limited period oftime. If mechanical issues 

arise, the sUAS can land immediately and will be operating from no higher than 400-

feet AGL. As provided in the Manual, the operator will insure that the sUAS is in 
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working order prior to initiating flight, perform required maintenance, and keep a 

log of any maintenance performed. Moreover, 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 . 

••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for 

publication in the Federal Register, should it be determined that publication is 

needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart 

H; 14 C.F.R. 45.23 (b); 14 C.F.R. §61.113 (a) & (b); 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) (1); 91.409 (a) (2); and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 pounds or less) in operations pertaining to (but not limited 

to) professional cinematography and commercial productions, aerial imaging for 

commercial and residential real estate use, aerial imaging for safty and monitoring 

of secured and controlled environments, aerial imaging for search and rescue ans 

well as assisting local laws enforcement and rescue crews. 

Approval of exemptions allowing commercial operations for sUASs in or 

industry enhances safety while reducing risk. Manned aircraft filming and surveying 

creates a greater risk because the crafts are much larger, have combustible fuel, and 

carry and on board human pilot. In contrast, a sUAS weighing fewer than 45 pounds 

and powered by batteries eliminates virtually all of that risk given. The sUAS will 

carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircrafts flights. 

The operation of sUASs, weighting less than 45 pounds, conducted in the 

strict conditions outlined above, will provide an equivalent level of safety 

supporting the grant of the exemptions requested herein, including exempting the 

application from the requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a 

sterile environment. As a result, they are far safer than conventional operations 

conducted with turbine helicopters operating close proximity to ground and people. 
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Privacy 

All flights will occur over private and controlled access property with the 

property owner's prior consent and knowledge. Images taken will be of individuals 

who have also consented to being filmed or otherwise have agreed to be in the area 

where aerial photography and cinematography will take place . 

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Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operations within visual line of sight and national security - provide more than 

adequate justification for the grant of the requested exemption allowing commercial 

operation of the applicant's sUASs in the filming and photography industry pursuant 

to the Manual appended hereto. 

Respectfully, 

Bradley 

u~ Shepherd 

President/CEO 

bradley@uptopimaging.com 

bradley@securedsurrounding.com 

+1.253.495.2223