**January 3, 2016**

Brett Clark 513 Spring Valley Drive Colum bia, TN 38401 Mobile: ( 931 ) 446
- 8750 Em ail: bclarkworld@gmail.com

Federal Aviation Adm inistration:
I, Brett Clark , am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I , Brett Clark , owner and operator of sm all unm anned aircraft, be exem pted fro m the Federal Aviation Regulations ( “ FARs” ) listed below so that I , Brett Clark , may operate a sm all ul tra light weight unm anned aircraft system ( “ UAS ” ) commercially in airspace regulated by the Federal Aviation Admi nistration ( “ FAA” ) in accordance with FAA UAS Regulations & Policies. I would like to formally subm it for an exem ption from the following Secti on 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1) , 14 C.F.R. 91.409(a)(1)and (2), 14 C.F. R. 91.417(a) and (b). to operate the Phantom 3P rofessional

. T his UAS wi ll

be equipped with on board cam era and will be transported in proper storage. This proposed
exem ption would allow the operation of unm anned aircraft systems (UAS) for the purpose of aerial videography/ photography as a service to the public/ business interests. As found in
exem ption No. 11138 (Trudeau), the FAA recently approved sim ilar use of aP hantom 2U AS. The Phantom 3P rofessional is sel ected because it has p roven / updated and reliable flying capabilities ma naged by gyro stabilized flight, ground detection ,GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and prop guards. This will act to further safety p rotocols exclusive to lightweight UAS’ s specific to video and photography usage as I, Brett Clark , record flight data and other information gained through perm itted flight operations to share wit h the FAA through any required FAA reports to assist with fut ure protocol and safety regulations.
**Specific section or sections of 14 CFR which we**  **seek relief and the reason we**  **seek relief:** 14 C.F.R. Part 21: Airworthiness Certificates Given the size and lim ited operating area associated with the aircrafts to be utilized by Brett Clark , an exem ption from Part 21 meets the requirem ents of an equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria dem onstrates that the UA operated without an airworthiness certificate, in the restricted environm ent and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: generalThe UA does not have a cabin, cockpit, pilot station, fuselage, boom , or tail on which to

mark certain words or phrases. Further, the two inch lettering is difficult to place on such a
sm all aircraft with dim ensions sm aller t han the minim al lettering requirement. 14 C.F.R. 61.113(a) &(b): Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional m anned airship experience of a commercially certified pilot would not correlate to the airm anship skills necessary for sim ilarly proposed operations in previously issued exem ptions to this regulation through Exem ption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Requires an aircraft flight m anual in the aircraft, however there are no pilots or passengers on board this aircraf t and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight m anual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I, Brett Clark, wi ll ensure that the UAS do not operate any higher than 4 00 feet at ground level. I will not fly over congested areas. I will plan operations via google m ap pro or other ma pping software before hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121 : Altimeter settings The UAS utilize electronic GPS with a barom etric sensor. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditionsThe UAS that I will fly is powered by electricity, using lithium polym er batteries that

currently have a flight limit of approxim ately no more than 20 m inutes. Therefore, due to the lim itations of the batteries, it is currently im possible to com ply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, Brett Clark , however will always fly safely while having the m anual of the Phantom 3 Professional C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance insp ections m ay be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I , Brett Clark , will perform preflight inspections of the UAS before each flight as outlined in the operating docum ents. I, Brett Cla rk, wi ll also follow manufacturer recommendations from said operating docum ents. **Public Interest** Aerial photography and videography as an available service to the public allows for a cheaper m ethod to capturing i magery than its alternative. The alternative being aircraft and helicopters. They are expensive, create lots of noise, and are m uch more threatening due to size and com bustible fuel. I, Brett Clark, wo uld gladly offer m y services upon request and with proper coordination to any official search and rescue or em ergency services organization to benefitthe public. This may be for Residential Construction, Real
-estate Marketing, Resort

Property Marketing, Wedding Videos, Commercial Photography, Cinem atography or Construction Site Progression im agery. Also as m entioned in the Trudeau exem ption, exem ption No.11138:

““ Manned aircraft conducting aerial film ing and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and m ay carry other onboard crewme mb ers, as well as 100 gallons or mo re of fuel. The petitioner’ s [ UAS] weighs less than 3 lbs. The pilot and
crew will be rem otely located from the aircraft. The lim ited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of
an onboard pilot and crew during an incident or accident is elim inated with the use of a [sUAS] for the proposed operation. ” **Summary** I, Brett Clark , am seeking exem ption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b) With the exem ptions of the m entioned rules I, Brett Clark , will be seeking to m ake Our drone photography/videography services available to the public. By not using com bustible fuel, flying at safe heights and strictly following the usage recommendations from Hubsan. T hese include but are not lim ited to:

• Flying the following UAS Safely

• Phantom 3 Professional● Flying below 4 00 feet

● Proper visual inspection of UAS before flights

● Keeping m entioned UAS in visual sight at all tim es when in operation

● Using an observer to assist if needed

● Rem ain well clear of and do not interfere with m anned aircraft operations, and avoid other aircraft and obstacles at all tim es
● Not intentionally fly over unprotected persons or m oving vehicles

● Contact the airport or control tower before flying within 5 m iles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensure the operating environm ent is safe

● Not flying over sensitive infrastructure or property such as power stations, water treatm ent facilities, correctional facilities, etc.

● Check and follow

all local laws and ordinances before flying over private property

● Do not conduct surveillance or ph otograph persons in areas where there is an expectation of privacy without the individual's perm ission. Respectfully, Brett Clark 513 Spring Valley Drive Colum bia, TN 38401 Mobile: ( 931 ) 446
- 8750 Em ail: bclarkworld@gmail.com