# Elevated Studios LLC **Chris Rosepink 20550 E Lake Circle** 

**Aurora, CO 80016 T**  **720-279-8554 chrisr@elevated-studios.com** 

**June 26, 2015** US Department of Transportation Docket Operations 1200 New Jersey Ave, SE Washington, DC 20590 RE: Exemption Request Section 33 of the FAA Reform Act of the Federal Aviation Regulations

Dear Secretary of Transportation, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Elevated Studios LLC requests to be exempted from the Federal Aviation Regulations (FAR) to allow commercial operation of its UAS with the operations before performed within the conditions outlined herein or by the FAA as required by Section 333. Elevated Studios LLC is an aerial photography and videography company using a DJI Inspire 1 UAS providing services for real estate and construction companies with marketing materials. Elevated Studios LLC is owned by Christopher Rosepink. I have hired a pilot for my flight operations, Jason Burnett. Mr. Burnett has a Commercial Pilot’s License and second class medical certification. Mr. Burnett will be the pilot in command, he will adhere to all FAA guidelines and will keep the public’s safety and right to privacy safe guarded at all times. The FAA has issued grants of exemption in similar circumstances in exemption numbers 11897, 11062, 11109, 11112, and 11213. Based on this Elevated Studios LLC is also requesting exemption for the use of a UAS in a commercial setting. The following information is provided based on the requirements for filing an exemption:
Contact Information Chris Rosepink 20550 E Lake Circle Aurora, CO 80016 720-279-8554 chrisr@elevated-studios.com Requesting Exemption from the following sections of Title 14 14 CFR 21, 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), 91.409(a)&(b) (2); 91:417(a)&(b)

PIC InformationJason Burnett Commercial Pilot, FAA 2718263 Second Class Medical Advanced Ground Instructor 4.25 hours with UAS 48 takeoffs and landings with UAS Performed training provided by the manufacturer online for the UAS

Visual Observer A visual observer will be used for commercial flights. The visual observer will be a second set of eyes to help ensure safety. The visual observer will be informed of their role prior to each flight which includes ensuring the UAS is keeping a safe distance from any objects and that people are not in any harm. The visual observer will be in close proximity of the PIC or use two-way radios to communicate with the PIC. UAS Operation and Safety The purpose of the commercial use of the UAS will be to provide photos and/or videos of real estate. This will not adversely affect safety since the UAS is very small it would be flown in a lim

ited area, the UAS is not carrying a pilot or crew, and does not carry flammable fuel. The UAS would be used over the property needing photos/videos which could be a residential house, a commercial property, or potential building site. The following will be considered as the binding limitation of operations for Elevated Studios LLC, Elevated Studios LLC uses a DJI Inspire 1 UAS weighing less than 55 pounds, operates at speeds less than 50 knots and has the capability to operate in the vertical and horizontal plane simultaneously. The UAS will operate only within the line of sight of the operator within a protected flight area and at 400 feet AGL or less. These will not present a hazard to the national airspace nor the public. The very small nature of these UAS being used in a limited area allows for the safe operation that exceeds requirements established by congress.
1. Flights will only occur in the day time hours.
2. Flights will be operated in the line of sight of the operator( PIC) and Observer (VSO). 3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” based on manufacturers recommendations.
4. The UAS will weigh less that 55 lbs.
5. Flights will be operated at 400 feet AGL or less.
6. Crew will be at a minimum the operator (PIC) and an Observer (VSO).
7. Operator and crew will remain in contact during the flight operation.
8. The UAS operator will perform a check of the flight area and make certain the safety of all persons in the area. 9. All required FAA clearances will be obtained and distances from airports strictly observed.10. The UAS has the capability to return automatically to the operator in a safe manner with the auto return function checked and working.
11. Flights will only operate in VFR conditions.
12. A pre-flight safety inspection will be performed on the UAS which includes checking to ensure the UAS is not damaged and all systems are functioning safely. 13. UAS has a function on the control to tell operator the distance away from the operator and its battery power remaining. If the UAS loses communications or GPS signal it will have capability to return to a pre-determined location and land.
14. Flight team will communicate by voice and the use of two-way radio if the area is too big to hear voice from all team members.
15. The maximum total flight time for each flight will be 20 minutes. Flights will be terminated at 25% battery power reserve if that were to occur during the 20 minute flight.
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.
17. The UAS will operate within the state of Colorado.
18. The UAS will never enter any restricted airspace or violate any TFR.
19. PIC and VSO will be trained in operation of the specific UAS.
20. Written and/or oral permission from the relevant property holder will be obtained. Images of people will rarely occur, but if they did we will obtain consent prior to operations.
21. We carry Professional Liability Insurance of 1.5 Million.

DJI Inspire 1 Specifications

Model T600 Weight (Battery Included) 6.47 lbs. Hovering Accuracy: Vertical 1.6 feet Horizontal 8.2 feet Max Angular Velocity 150 degrees Max Tilt Angle 35 degrees Max Ascent Speed 16.4 ft/s Max Decent Speed 13.1 ft/s Max Speed 42 kts Max Flight Time 20 minutes Operating Temperature Range 14-104 degrees farenheit Dimension 18”x18”x12”

CameraModel: FC350 Total Pixels: 12.76M Image Max Size: 4000x3000 FOV (Field of View): 94 Degrees Lens: 20mm (35mm format equivalent)f/2.8 focus at Infinity 9 Elements in 9 groups Anti-distortion Still Photography Modes: Single Shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time-Lapse Video Recording Modes: UHD (4k) 4096x2160p24/25, 3840x2160p24/25/30 FHD 1920x1080p24/25/30/48/50/60 HD 1280x720p24/25/30/48/50/60 Max Bitrate of Video Storage: 60 Mbps 14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Elevated Studios LLC operations center.
14 CFR 91.7 (a) prohibits the operation 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) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. 14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Elevated Studios LLC will only operate its UASs at or below 400AGL. They will be operated on a well defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has consented and all persons within this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public. Summary Approval of these 333 Exemptions allowing commercial operations of small UAS in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UAS of 55 lbs. or less, battery operated and flying below 400 feet AGL the risk of injury to people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Elevated Studios LLC will give the people another avenue to obtain aerial photography and videography. I appreciate your time regarding this matter and look forward to your response.Sincerely,

Chris Rosepink