Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 1 of 10 May 5, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Subj: Petition for Exemption to Operate the DJI Phantom 2 Vision+ V3.0 Quad

- Copter Unmanned Aerial System for Commercial Aerial Photography and Videography Purposes

Dear Sir or Madam:

I, Michael Sliter, owner of Hotwire Productions.net, LLC., am writing pursuant to the FAA Modernization and Reform Act of 2012 and the p rocedures contained within 14 C.F.R. 11, to request that Hotwire Productions.net, LLC, a multimedia, photography and videography business, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that we may operate
a small ultra

- lightwei ght unmanned aircraft system (“sUAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Michael Sliter, am chief photographer / videographer at Hotwire Productions.net, LLC., which has acquired a DJ I Phantom 2 Vision+ "V3.0" Quadcopter with FPV HD Video Camera with intent to operate it for commercial aerial photography / videography following exemption and approval by the FAA.

I am well acquainted with the risks that come with the privilege of oper ating an aircraft in the United States, but also with the opportunities available via new unmanned flight technology. I
have made numerous flights as a hobbyist and have accumulated more than twenty hours ( 2 0) of logged flight time with the unmanned aircraft that is the subject of this Petition. I would like to combine the benefits of an unmanned aviation platform with my existing profession as a web developer, photographer and videographer to further the opportunities for safe, cost

- eff ective aerial imaging services for the public at large. I, Michael Sliter, will serve as chief pilot at Hotwire Productions.net, LLC. for the proposed use of the sUAS.

Exemption request would permit operation of ultra

- light weight, unmanned (piloted by r emote control) and comparatively inexpensive sUAS(s) in tightly controlled and limited airspace photographing or videographing within property boundaries of individual property owners with their permission.

Appendix A

– Hotwire Productions.net, LLC Operating Procedures

Attachment B

– DJI Phantom 2 Vision + (User Manual V1.8 )Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 2 of 10 I. Contact Information:
Michael Sliter

, Hotwire Productions.net, LLC.

PO Box 339
1313 Somerset Road London, Kentucky 40743

- 0339

Phone: 606

- 682

- 6799
Email: michael@hotwireproductions.net
Website: www.hotwireproductions.net

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Hotwire Productions.net, LLC Requests Exemption are: 14 C.F.R. Part 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); 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);

9 1.417(a)&(b)

III. The Extent of relief Hotwire Productions.net, LLC seeks and the Reason He Seeks Such Relief:
I, Michael Sliter , submit this petition in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicabl e FARs operating to prevent Hotwire Productions.net,
LLC’s contemplated commercial use of an sUAS for photographic and videographic use within the national airspace system. The Reform Act in Section 332 provides for such integration of civil
unmanned aircr aft systems into our national airspace system as it is in the public’s interest to do

so. Hotwire Productions.net, LLC’s ultra

- lightweight sUAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra

lightweight sUAS is expressly contemplated by the Reform Act.

The Reform Act guides the Secretary in determining the types of sUASs that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the sUASs; whether the sUAS will be operated near airports or heavily populated areas; and, whether the sUAS will be opera ted by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for Hotwire Productions.net, LLC. My sUAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My sUAS is equipped with
GPS and a uto return safety technology. My sUAS weighs less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, Michael Sliter , consider safety the utmost importance with every flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 12 knot (13 mph). Built in safety systems include a GPS mode that allows my sUAS to hover in plac e when radio controls are released. When pilot communication is lost, the sUAS is designed to slowly descend to the point of take

- off. Hotwire Productions.net, LLC will not operate sUAS near airports, Hospitals nor Police heliports, and will
not operate ne ar areas where general public is within thirty to one hundred (30

- 100) yards depending on location, conditions and weather. We utilize a crew of two (2), a pilot (“PIC”), and

a spotter who are constantly on alert for any manned aircraft (Police/Medical hel icopters, etc.)Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 3 of 10 and prepared to land / abort immediately to the nearest and safest ground point should a manned aircraft approach the area of operation.

Our sUAS is capable of vertical and horizontal operations, and is flown only within line of sight of the PIC. Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to fifteen (15) min u tes, with an altitude under two hundred ( 200 ) feet. Hotwire Productions.net, LLC will utilize a fresh fully charged battery with ea ch flight as a safety precaution; full flight time limit for each battery is twenty (20) to twenty

- five (25) minutes as
tested. Hotwire Productions.net, LLC will not operate sUAS at or below the manufacturer recommend minimum charge levels for operation; p referring to remain well within a safe operating range to insure adequate communication between radio control and sUAS to eliminate potential for crash, loss of control or hazards. Reserve batteries are at hand with each mission to insure replacement for s ufficient safe level of operation. We do not take any risks that may cause a crash, which could create hazards to the public / property / manned aircraft, and we have no
desire to lose or damage our investment. I have completed dozens of practice flights i n remote areas on private property as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of this specific sUAS’s performance under different temperature and weather conditions.

I, Michael Sliter, will be Hotwire Productions.net LLC’s chief pilot

. I am extremely cautious when operating our sUAS / 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 sUAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate sUASs into the national airspace system. My Phantom 2 sUAS, used i n hobby flight, has a demonstrated safety record and does not pose any threat to the general public.

IV. How Hotwire Productions.net, LLC’s Request Will Benefit the Public As A Whole: Hotwire Productions.net, LLC is a small business serving customers in need of professional quality web de sign, photography and videography. We are interested in providing aerial photography and videography services to realtors , private property owners and business owners
located in South

- East ern Kentucky

. For many, the expense of aerial photography and videography using manned aircraft is cost prohibitive. The advent of sUAS’s used in this business environment, and their ability to produce unique images will not only help our small business compete with larger busine sses, but also provide our realtor customers with their own new business value, thus promoting commerce and economic development. Permitting Hotwire Productions.net, LLC to immediately fly within national air space furthers economic growth in
our South

- Eas t ern Kentucky area, and provides a definite benefit to the Realtors and property/business owners looking to use aerial photography and videography, both of which increase commerce and serve as a benefit and stimulus to the area economy and community.Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 4 of 10 V . Reasons Why Hotwire Productions.net, LLC’s Exemption Will Not Adversely Affect Safety or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: Hotwire Productions.net, LLC has the utmost respect for everyone’s safety and comf ort. As it concerns to sUAS operations:

1. Our sUAS (DJI Phantom 2 Vision+ "V3 .0" Quadcopter with FPV HD Video Camera) weighs less than 5 pounds;

2. Each mission will consist of a crew of 2: one PIC and one spotter;

3. The PIC will have a minimum of 20 logged fli ghts and 2 0 total hours in the make and model of the operating sUAS, including at least 3 flights in the last 90 days;

4. We only operate our sUAS below 200 f eet in day VFR conditions ( well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);

5. We will not operate the sUAS in Class A, B, C, or D airspace without written approval from the FAA;

6. We will not operate within 3 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA

- published aero nautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request;

7. During operation of the sUAS, signs will be posted warning the public that: “Caution: Small Unmanned Aircraft Operation in Progress”;

8. If any unauthorized person moves within 200 feet of the operating sUAS, the mission wil l be aborted immediately;

9. Our sUAS only operates for ten ( 10 ) to fifteen (1 5 ) minutes per flight, severely limiting the exposure of any safety concerns towards the public or property;

10. W e pilot our sUAS through remote control only by visual line of sight, keeping the sUAS within 500 feet of the operator at all times;

11. Our sUAS has GPS controlled failsafe, a flight safety feature whereby it hovers and then slowly lands if communication with the remote cont rol pilot is lost;

12. We log flight data and other sources of information to constantly update and enhance safety protocols;

13. Before each flight we assess the environment and we only proceed to operate in reasonably safe environments that are controlled, are away from power lines, elevated lights, airports and actively populated areas;

14. We conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance;

15. We always obtain all necessary permissions prior to operation; and we h ave procedures in place to abort flights in the event of safety breaches or potential danger.

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.Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 5 of 10 1. 14 C.F.R. 21, Sub part 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 Hotwire Productions.net, LLC’s sUAS permits exemp tion from Part 21 because our sUAS meets (and exceeds) 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 sUASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense

po pulations. Hotwire Productions.net, LLC’s sUAS meets or exceeds each of the
elements.

2. 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.

3. 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 sUASs, this Regulation is inapplicable. An equivalent level of saf ety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 107 00 and 32827.

4. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our sUAS utilizes electronic global positioning systems with a barometric sensor, and altitude information will be provided to the pilot via a digitally encoded telem etric
datalink to a real

- time display.

5. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. H otwire Productions.net, LLC request s exemption from this FAR insofar as it mandates issuance of an airworthiness certificate, for
the reasons stated in my request for an exemption under 14 CFR Part 21, Subpart

H.

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 sUASs are, by definition, unmanned. They t herefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Hotwire Productions.net, LLC requests an exemption from this part . The FAA has previously issuedExemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 6 of 10 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), t he petitioner requests an exemption that would allow him to operate the Subject UAS for compensation or hire as part of his aerial photography bu siness for
the reasons articulated in In re Trudeau , FAA Exemption No. 11138, and In re Astraeus

, FAA Exemption No. 11062. Hotwire Productions.net, LLC will operate the s UAS over property where the owner or owner's representative has requested that the ope ration occur. Furthermore, since I meet the knowledge base and skill level for operating an UAS

, I request an exemption from the requirement that I hold a commercial pilot certificate and anything other than a Third Class Medical certificate.

D. 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. Our sUAS will never operate at an altitude greater than 2 00 feet AGL, only in safe areas away from the pub lic and traffic. Given the small size and weight of the sUAS, its maneuverability and speed profile, we can achieve an equivalent level of safety

.

E. 1 4 CFR § 91.151(a) requires a thirty (30) minute fuel reserve for flight in VFR conditions.
Since maximum fl ight time is limited to battery capacity, and is less than 30 minutes for our sUAS, we will operate our sUAS for no longer than ten (10) to fifteen (15) minutes on a full charge. A full charge would allow for a flight time of at least twenty (20) minutes, providing a 25% to 50% safety margin. The FAA has previously issued exemptions for manned aircraft to operate at less than the minimums prescribed in 14 CFR § 91.151(a), including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific reli ef has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions.

F. 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 thing s, 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. . . .”

To comply with this regulation, the PIC, before each mission, will check the

m anufacturers’ internet service pages, and ensure applicable software and hardware is up to date as required, and ensure compliance with any safety bulletin s posted. In addition, the Operators Manual as provided by the sUAS manufacturer will be revised to include specific operating procedures and limitations to comply with the exemptions sought as described in section V (see appendix A). The revised Operators Manual will be in possession of the crew during operation of the sUAS, and must be made available to the Administrator or any law enforcement official upon request.Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 7 of 10 In summary, Hotwire Productions.net, LLC 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; 1 4 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); and, 14 C.F.R. § 91.417(a) & (b) to commercially operate Hotwire Productions.net, LLC’s small , ultra

- lightweight, unmanned aerial vehicle (sUAS ) in aerial photography and videography operations. Hotwire Productions.net, LLC will utilize safety protocols and the implementation of flight operati n g p rocedures that exceeds currently accepted means and methods for safe flight. Hotwir e Productions.net, LLC’s operation of the sUAS, weighing less than 5 pounds and travelling at low speeds within limited controlled areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly Hotwire Productions.net, LL C respectfully requests that the FAA grant our exemption request.

Conclusion I would like to thank the FAA for considering this request. Please do not hesitate to contact me
should there be a need for addi t ional information. I look forward to working with the FAA in its determination, and to being a part of the discussion as the FA A consid ers how to expand and
control commercial UAV use in the United States.

Respectfully submitted,

Michael Sliter , Photographer / Videographer, Owner Hotwire Productions.net, LLC

PO Box 339
1313 Somerset Road London, Kentucky 40743

- 0339

Phone: 606

- 682

- 6799

E

- mail: michael@hotwireproductions.netExemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 8 of 10 Appendix A

– Hotwire Productions.net, LLC’s Operating Procedures

Safety is our main concern. Owner and crew must be familiar with, and follow these operating procedures:

1. Owner must:

a. Document all maintenance, alterations, and updates in the aircraft records.

b. Any maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator’s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records
of th e flight.

2. Prior to each mission:

a. The PIC must familiarize him/herself with all possible safety aspects of the
mission. This includes but is not limited to:

i. Software versions required (manufacturers web site)

ii. Weather

iii. Wind (less than 12 knots)

iv. NOTAMS

v. Proximity of airports or SUA

3. Prior to each flight:

a. T he PIC must inspect the sUAS and Ground Station to ensure they are in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohi bited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. This includes but is not limited to:

i. Batteries (full sUAS battery required for each flight, check battery levels
for transmit ter and range extender)

ii. Inspect propellers, motors, wings and lights

iii. The documents required under 14 CFR §91.9 and §91.203 must be available to the PIC at the Ground Control Station of the sUAS any time the aircraft is operating. These documents must be m ade available to the Administrator or any law enforcement official upon request.

b. T he PIC performs a safety assessment. This includes but is not limited to:

i. If operating within 3 miles of an uncontrolled airport, check that a letter of agreement that cover s the current mission with the airport manager is available to the PIC, and that the operation is conducted under a current

NOTAM.

ii. Inspect flight area for light poles, trees, utility wires, proximity to helipads, hospitals, schools, busy roadways, gatherin gs of people, SUA.

iii. The PIC provides a safety briefing to the spotter. An agreement is made under which conditions the flight must be aborted.Exemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 9 of 10 iv. Check placement of warning signs: “Caution: Small Unmanned Aircraft Operation in Progress”

v. Identify take

- off and landing area.

c. The PIC performs pre

- flight checks:

i. Check all controls neutral

ii. Turn on Power transmitter first, then on sUAS, and Range Extender

iii. Perform GPS alignment according to manufacturer’s operating manual

iv. If alignment successful, flight can start from a safe take

- off point

v. Immediately after takeoff perform the following checks:

1. Hover 5

- 10 feet

2. Check data link

3. Check video link

4. Check altimeter

5. Check GPS

6. Check time

d. During each flight:

i. The sUAS may not be operated by the PIC from any moving device or
vehicle.

ii. The sUAS may not be operated at an altitude exceeding 2 00 feet AGL.

iii. The sUAS may not be operated at night or at altitudes less than 500 feet below or less than 2,000 feet horizontally fro m a cloud or when visibility is
less than 3 statute miles.

iv. The sUAS must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasail ing activities, hang gliders, etc.).

v. Flight time is limited to maximum fifteen (15) minutes.

vi. sUAS must remain within line of sight and within 500 feet of PIC.

e. Emergency during flight. This could include but is not limited to:

i. Pilot distracted

ii. Spotter si gnals abort

iii. Sudden change in weather or wind

iv. Manned aircraft in the vicinity

v. People getting within safety perimeter

vi. Birds

Immediately:

i. Determine closest safe landing location to sUAS

ii. LandExemption Request Michael Sliter, Hotwire Productions.net, LLC.

Page 10 of 10 f. After each flight:

i. Check and log flight time and remaining battery level.

ii. Turn off power to sUAS first, then turn off power to transmitter and range
extender

. iii. Inspect sUAS for any damage

. iv. Remove warning signs

Attachment B

– DJI Phanto m 2 Vision+ (User Manual )

T he PDF version of the DJI Phantom 2 Vision+ User Manual exceeded the 10.5 MB file

- size upload limit on the Regulations.gov website ’ s comments section.

The full user manual can be downloaded directly from the manufacturer ’ s website in PDF format

at the following URL:

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual _v1.8_en.pdf