Hagood Photography

1450 E. Overbrook Road

Millbrook, AL 6054

334

- 410

- 0746

U.S. Department of Transportation

Federal Aviation Administration

October 23, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal
Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR
91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR
91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a)
and (b)

Dear Sir or M adam,
Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of
2012 (the “Reform Act”) and 14 CFR Part 11, David Hagood, Owner of Hagood Photography which owns and operates an Un manned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may b e established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

- Aerial photography and/or video for public and/or private use including real estate,
architecture, surveying, engineering and other related professional activities.

- Aerial video and/or photography for public and/or private use including television, public
events, private events, cinematography and news gathering.- Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

- Aerial inspection/photography or residential/commercial utility infrastructure including but not
limited to electrical power lines, wind turbines and cell towers.

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- Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of emergency or natural disaster only when the local authorities or government has requested it by contract or donation. Hagood Photography operates one DJI Inspire 1 (4) blade quad copters weighing 6 pounds, 7.5 ounces (see attached manual). The UAS has a maximum airspeed of 40 miles per hour and uses a remote controller operating on frequen cy range of 2.400

- 2.483 GHZ. The Inspire 1 is equipped with built

- in ground support technology that allows it to fly utilizing global positioning system (GPS) for stability, tracking, safe flight mode and a return

- to

- home feature in the event of loss of re mote control signal or critical low battery. All flights start with a pre

- flight safety check and all flight data are recorded. The Inspire 1 is equipped with a gimbal mounted camera that sends a live video signal to the controller allowing the person in c ontrol (PIC) to monitor real

- time video. Flight data, speed height, distance, battery level and general aircraft conditions are also displayed during operation. The Inspire 1 battery has a flight time of 15

- 20 minutes and is, therefore, always returned to original takeoff point and always flown utilizing visiual line of sight (VLOS). We have been training on the DJI Inspire for seven months and have become proficient in all aspects of flight and safety of this UAS. Our request for exemption would allow us t o offer unique aerial photography and videography services to our clientele.
UAS Safety Operating Parameters
We will abide by the following additional operating conditions under this exemption, which ensures a level of safety during UAS flight including op erating the UAS below 400 feed and within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such

v essels, vehicles or structures. We will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard. Other safety operating parameters include:

- Operate the UAS for 15

- 20 minutes per flight.

- Land UAS prior to the manufacturers recommended minimum level of battery power.

- Operate the UAS during daylight hours only within VLOS.

- Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands i f communication with the PIC is lost or battery becomes critically low.

- Always obtain all necessary permissions prior to operation.

- Have procedures in place to abort flights in the event of safety breaches or potential danger.- Review weather reports prior to flight and never operate UAS in unsafe conditions, high wind, low

clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely popul ated areas.

- Also conduct extensive preflight inspections and protocols during which safety carries primary importance.

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The PIC will also have a minimum of five hours logged on this craft and 10 hours minimum flying UAS

quad copters under varying condit ions and environments and will follow all safety protocol of B2 Aerial
as well as guidelines of 14 CFR §61.51(b) having the ability to safely operate the UAS in a manner

consistent with the operating documents, including evasive and emergency maneuvers and maintaining
appropriate distances from people.
Specific Exemptions Requested
Given the size, weight, speed and limited operating area associated with the UAS, we feel an exemption
from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.2 03(a) and (b) (certifications
required), subject to certain conditions and limitations, is warranted and meets the requirements for an
equivalent level of safety under 14 CFR Part 11 and Section 333 of P.L. 112

- 95 (Section 333).
We request an exemption fro m 14 CFR 45.23 Marking of the Aircraft because the UAS will not have a
cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering
is difficult to place on such a small aircraft with dimensions smaller than th e minimal lettering
requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the
word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will see the markings.
We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in
Command. The applicant’s UAS do not carry any pilots or passengers nor property. The Risks attendant
to the operation of the UAS is far less than the r isk levels inherent in the commercial activities outlined
in 14 CFR §61. The operation and limitations in the flight operation manual (FOM) will equate to the safe
operations of the UAS.We request an exemption from 14 CFR 91.7(a) which prohibits the opera tion of an aircraft without an

airworthiness certificate, since there is currently no certificate applicable to our operation, this
regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR
91.409(a)2) and 14 CF R 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with
an airworthiness certificate. However, as a safety precaution, we will perform a preflight inspection of
the UAS before each flight as outlined in the attached operating doc uments.
We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft,
however, since there are no pilots or passengers on board the aircraft, and given its size, this regulation
is inapplicable. We believe an equivalent lev el of safety will be achieved by maintaining a safety/flight

manual with the UAS ground station.
We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and
Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is being used
for flight instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 is
capable of dual/linked controls, we will be operating with a single remote controller.

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We request a n exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of
civil aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not
operate our UAS above the altitude of 400 feet above ground l evel (AGL) and will also only operate in
safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or
below those in relation to minimum safe altitudes.” Given the size, weight and maneuverability and
speed of th e UAS, an equivalent or higher level of safety will be achieved.
We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the UAS
utilizes electronic GPS with a barometric sensor. We request a n exemption from 14 CFR 91.151(a) Fuel
Requirements for Flight in visual flight rules (VFR) conditions. The UAS is 100 percent electric and two

low battery alerts are issued

– per the operating documents, the UAS will be landed at the first alert.Also, ou r flights will last only 15

- 20 minutes each and the UAS has an automated function, which results

in immediate landing when a low battery is detected. The PIC will not begin a flight unless, considering
wind an forecast weather conditions, there is enough p ower to fly to the first point of intended landing
and, assuming normal cruising speed, land the UAS with 30 percent battery power remaining.

Summary
We will comply with all of the following conditions and limitations should this grant of exemption be

prov ided:
1. Operations will be limited to the following aircraft described in the operating documents which

is a quad

- rotor aircraft weighing less than seven pounds: DJI Inspire 1 Aircraft System.
2. The UAS will not be flown at an indicated airspeed exceedin g 40 mph.
3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the
procedures specified in the operating documents.
4. The UAS will be operated within VLOS of the PIC at all times.
5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS of the

VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be
designated before the flight and will not transfer his or her designation for the duration of t he
flight. The PIC will ensure that the VO can perform the functions prescribed in the operating

documents.
6. The operating documents will be accessible during the UAS operations and made available to
the Administrator upon request. Any revisions to the o perating documents will be presented to
the Administrator upon request.
7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the
inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be
operated until the necessary maintenance has been performed and the UAS is found to be in a
condition for safe flight. The Ground Control Station will be included in the preflight inspection.All maintenance and alterations will be properly documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
replacement of a flight critical component, will undergo a functional te st flight. The PIC who
conducts the functional test flight will make an entry into the aircraft records.

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9. The pre

- flight inspection section in the operating documents will account for all discrepancies,
i.e. inoperable components, items or equipment no t already covered in the relevant sections of
the operating documents.
10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection and life limit requirements.
11. We will carry out maintenance, inspections and record

- keeping requirements, in accordance
with the operating documents. Maintenance, inspection and alterations will be noted in the
aircraft records, including total flight hours, description of work accomplished and the signature
of the authorized p erson returning the UAS to service.
12. Each UAS operated will comply with all manufacturer Safety Bulletins.
13. An authorized person will make an entry in the aircraft record of the corrective action taken
against discrepancies discovered between inspect ions.
14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in

which the PIC is rated on.
15. Prior to operations conducted for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and
logged, in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot
operating the make and model of the UAS to be used in operations.
16. The PIC will not operate t he UAS for the purpose of aerial videography/cinematography and
augmenting real estate listing videos (or similar operations), unless the PIC has demonstratedand logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in

a manner consistent with the operating documents, including evasive and emergency
maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
17. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All operations
will be conducted under visual meteorological conditions (VMC).
18. The UAS will not operate within five nautical miles of an airport reference point as de noted on a

current FAA

- published aeronautical chart.
19. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a
cloud or when visibility is less than three statute miles from the PIC.

20. If a UAS loses communicat ions or loses its GPS signal, it will return to a predetermined location
within the planned operating area and land or be recovered in accordance with the operating

documents.
21. The PIC will abort a flight in the event of unpredicted obstacles or emergen cies in accordance
with the operating documents.
22. The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is
enough power to fly at a normal cruising speed to the intended landing point and land the UAS
with 30 pe rcent battery power remaining.
23. Before conducting operations, the radio frequency spectrum used for operation and control of
the UAS will comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requiremen ts.
24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the PIC at
the Ground Control Station of the UAS at any time the UAS is operating. These documents will
be made available to the Administrator or any law enforcement o fficial upon request.

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25. The UAS will remain clear and yield the right of way to all manned aviation operations andactivities at all times.

26. The UAS will not be operated by the PIC from any moving device or vehicle.
27. The UAS will not be operated over congested or densely populated areas unless contracted out

to do events.
28. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels,

vehicles and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from
the UAS and/or debris in the event of an accident. We will ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparti cipating
persons leave such protection and are within 500 feet of the UAS, flight operations must
cease immediately.
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has gra nted permission and the PIC has made a
safety assessment of the risk of operating closer to those objects and determined that it
does not present an undue hazard.
c. Operations near to the PIC, VO, operator trainees or essential persons do not present an

u ndue hazard to those persons per 14 CFR 91.119(a).

29. All operations will be conducted over private or controlled

- access property with permission
from the land owner/controller or authorized representative. Permission from land
owner/controller or authori zed representative will be obtained for each flight to be conducted.
30. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of
the operational area as defined by the applicable certificate of authorization (COA) will be
reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be
reported to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB website: www.ntsb.gov

.On behalf of Hagood Photography , I would like to thank you for your consideration in granting this

exemption.
Signed,
David Hagood
Hagood Phtoography