July 9, 2015

Jonathon E. Doss, Owner Sublime Media Group, LLC 1225 Shawnee Way Bowling Green, KY 42104 Cell (270) 543-4501 Email: jon@sublimemediagroup.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act 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; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam, I, Jonathon E. Doss, 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, Jonathon E. Doss, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Jonathon E. Doss , may operate my small ultra lightweight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein I, Jonathon E. Doss, am a small business owner within the Commonwealth of Kentucky; experienced in flying hobby typehelicopters for recreational purposes. I have added a hobby grade quadcopter UAS (DJI Phantom 2) to my inventory, equipped with a GoPro camera with intent for aerial videography/cinematography to augment television commercials, corporate videos, wedding and event filming

, promotional videos; following exemption and approval by the FAA.

My exemption request would permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace - predetermined in areas away from general public, airports, heliports and vehicular tra ffi c for community videos, and within property boundaries for private business and property videos/photos. Currently, unmonitored amateur hobbyistsJuly 9, 2015

with no safety plan or controls in place to prevent catastrophe legally operate similar lightweight, remote controlled UAS’s in the National Airspace System. I, Jonathon E. Doss, have personally established safety protocols to avoid public hazard. Granting my request conforms with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the ” under Section 333(c) of the Reform Act specific to the use of UAS's for commercial photography and videography purposes. Further I, Jonathon E. Doss, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Jonathon E. Doss, respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to enhance television commercials, corporate videos, wedding and event filming, and promotional videos for clients who cannot

a ff ord expensive manned aircraft. This will promote local economic growth through increased employment and increased tax base. This will keep public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard.

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Jonathon E. Doss Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Jonathon E. Doss seeks and the Reason He

Seeks Such Relief: I, Jonathon E. Doss, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Jonathon E. Doss, contemplated commercial cinematic, academic and other flight operations within theJuly 9, 2015

National Airspace System. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our National Airspace System as it is in the public’s interest to do so. My ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft.

Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all commercially related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our National Airspace System. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, whether the UAS will be operated by line of sight. Each of these items reflects in favor of an exemption for me, Jonathon E. Doss. My UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55-pound limit); including camera with gimbal.

I, Jonathon E. Doss, consider safety foremost with each flight. My smallunmanned aircraft is designed to hover in place via GPS and operate in less than a 24-knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When communication is lost, the UAS is designed to slowly descend to point of

take o ff

.

I, Jonathon E. Doss, do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location,

c onditions and weather. I am constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location.July 9, 2015

My UAS is capable of vertical/horizontal operations, and are flown only within my line of sight (LOS) of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (5) to seven (10) minutes, with an altitude under one hundred fifty (150) feet. I, Jonathon E. Doss, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is up to twenty-five (25) minutes. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation. I prefer to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for su ffi cient safe level of operation. I do not believe in taking risk that may cause a crash, which could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have practiced extensively with flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance

under di ff erent temperature and weather conditions.

I, Jonathon E. Doss, am extremely cautious when operating of my UAS/ ultra lightweight unmanned aircraft and will not “create a hazard to users of the National Airspace System or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the National Airspace System. Jonathon E. Doss’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How Jonathon E Doss’ s Request Will Benefit the Public As A

Whole: Aerial videography for television commercials and otherwise has been around for a long time through manned fixed-wing aircraft and helicopters. For small budget production companies and wedding/event videographers, the expense of such aerial videography is cost prohibitive. Only large companies can a ff ord to absorb such expense, depriving nonsmaller production companies from a valuable marketing tool. My UAS poses no threat, since size and lack of combustible fuel alleviates any potential threat to the public.July 9, 2015

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the National Airspace System, hence the passing of the Reform Act. Granting my, Jonathon E. Doss’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around Kentucky. My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra lightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting me, Jonathon E. Doss, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the local community for companies looking to relocate or build in the Commonwealth of Kentucky, as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Jonathon E. Doss’s Exemption Will Not Adversely

A

ff ect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Jonathon E. Doss’s, exemption will not adversely a ff ect safety. Quite the contrary, for the reasons stated permitting me, Jonathon E. Doss, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for other individuals and development in cooperation with the FAA. In addition I, Jonathon E. Doss, submit the following representations of enhancements to current aerial videography and photography for commercials, events and other opportunities, which may present itself:

My UAS weighs less than 5 pounds complete with a small ultra lightweight high quality built-in camera; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate for 5-10 minutes per flight; I will land my UAS prior to manufacturer recommended minimum level ofJuly 9, 2015

battery power; I pilot my UAS through remote control only by visual line of sight (VLOS); My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, Jonathon E. Doss’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our small business, helicopters are the primary means of commercial aerial video and photography.

The potential loss of life is diminished because UAS's carry no people on board, and I only operate my UAS in specific areas away from mass populations. There is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. The small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.

Accordingly, my UAS has been operated for familiarization and competency and will continue to operate at and above current safety

levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Jonathon E. Doss’s , UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act.July 9, 2015

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations.

My, Jonathon E. Doss’s, current UAS meets or exceeds each of the elements. 14 C.F.R. 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 the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined.

The FAA previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others.

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable, as my UAS uses electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me,

Jonathon E. Doss.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is di ffi cult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV willJuly 9, 2015

see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Jonathon E. Doss, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Jonathon E. Doss, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL, safely below the

standard of 400 AGL.

I, Jonathon E. Doss, will operate my UAS in safe areas away from public

and tra ffi c, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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 . . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Jonathon E. Doss’s, UAS. However, as a safety precaution, I inspect my UAS before and after each flight.July 9, 2015

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21

and 14 C.F.R.

91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Jonathon E. Doss’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 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 the FARs, this Regulation is inapplicable. 14 C.F.R. § 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 UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Jonathon E. Doss , seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 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(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Jonathon E. Doss’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, at commercial shoots, wedding and events and other opportunities which may present itself. Currently, commercial and eventJuly 9, 2015

aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public.

Granting my, Jonathon E. Doss’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS aircraft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional commercial video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from

established airfields.

I, Jonathon E. Doss, have been informally analyzing flight information and will compile safety protocols and the implementation of flight operation for commercial and event filming usage that exceeds currently accepted means and methods for safe flight.

There are no personnel on board my, Jonathon E. Doss’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Jonathon E. Doss’s, operation of my UAS, weighing less than 5 pounds and traveling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs.

I, Jonathon E. Doss, respectfully request that the FAA grant my exemption request, and I am more than willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully,

Jonathon E. Doss, Owner Sublime Media Group, LLC d.b.a Sublime Wedding Films 1225 Shawnee Way Bowling Green, KY 42104