16164 Lakeside Ave SE Prior Lake, MN 55372

T 952-440-5422 C 612-839-8320 cmewert@integraonline.com DEVOR PRODUCTIONS, LLC

Mark Ewert - President/Owner

September 2, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE West Building Ground Floor, Room W12-140 Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR Part 21 Subpart H, 14 CFR 61.23(a) and (c), 14 CFR 61.113(a) and (b), 14 CFR 61.101(e) (4) and (5), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417 Dear Sir or Madam; Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R Part 11, Devor Productions, LLC, an operator of Unmanned Aircraft Systems (“UASs”) for aerial photography and videography for the real estate, motion picture and television industry, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its small unmanned aircraft system (“UAS”) in airspace regulated by the Federal Aviation Administration (“FAA”). Devor Productions, LLC’s requested exemption would permit the operation of a small, unmanned UAS under 55 pounds to conduct aerial video and photography under the operational control of a individual holding at least a Private Pilot certificate; under direct control of a Pilot in Command (PIC); within Visual Line Of Sight (VLOS); while utilizing a second person for the purpose of a Safety Observer. As established by the exemptions already granted by the FAA, approval of Devor Productions, LLC’s exemption would enhance safety and fulfill the Secretary of Transportations (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. The name and address of the applicant is: Devor Productions, LLC ATTN: Mark Ewert T: 952-440-5422 email: cmewert@integraonline.com Address: 16164 Lakeside Ave SE Prior Lake, MN. 55372 Regulations from which the exemption is requested: 14 CFR Part 21 Subpart H, 14 CFR 61.23(a) and (c), 14 CFR 61.101(e)(4) and (5), 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119,14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417 The UAS operated by Devor Productions, LLC weighs less than 55 pounds, including the payload (i.e. camera, lens and gimbal). It operates at a speed of no more than 50 knots, can hover and can move vertically and horizontally, simultaneously. Devor Productions, LLC will only operate its UAS in line of sight, below 400 feet AGL and operate under the control of a FAA certified private pilot with a additional person as a safetyobserver. Such operation will ensure that the UAS will “not create a hazard to users of the national airspace system or the public.” Given the small size of Devor Productions, LLC’s UAS and the safety considerations proposed in this petition, Devor Productions, LLC’s UAS operations adhere to the Reform Act’s safety requirements. Additionally, due to the size of the UAS and the proposed use in which it will operate, approval of this application presents no national security issues. Based on the level of safety surrounding the proposed operations, and the significant public benefit: marketing of real estate, corporate employee safety training, increase in local revenue and the reduction of environmental impacts such as emissions and noise from no longer using helicopter services for the same purposes, the grant of the requested exemption is in the public interest. Accordingly, Devor Productions, LLC respectfully requests that the FAA grant the exemption.

Page 2Aircraft and Equivalent Level of Safety The operating limitations proposed by Devor Productions, LLC provide for at least an equivalent or higher level of safety to operations under the current regulatory structure. Devor Productions, LLC agrees to be bound when conducting UAS operations. The list of limitations and conditions include the following: Operations authorized by this grant of exemption is limited to the DJI Inspire when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. Operations for the purpose of closed-set motion picture and television filming are permitted. The UA may not be operated at a speed exceeding 50 knots (57 miles per hour). The exemption holder may use either ground speed or calibrated airspeed to determine compliance with the 50 knot speed restriction. In no case will the UAS be operated at airspeed greater than the maximum UAS operating airspeed recommended by the aircraft manufacturer. Flights will be operated at an altitude of no more than 400 feet AGL and not more than 200 feet above an elevated platform from which filming is planned. An FAA licensed airman with at least a private pilot’s certificate will oversee flight operations to ensure the highest degree of safety. The UAS must be operated within visual line of sight (VLOS) of the pilot in charge (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. All operations must utilize a Visual Observer (VO). The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his/her designation for the duration of the flight. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in condition for safe flight. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection and life limit for the aircraft and its components. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not permitted. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airports management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement must be made available to the Administrator or any law enforcement official upon request.

Page 3If the UAS loses communication or loses its GPS signal, the UAS will have the capability to return to a predetermined location and land. The location will be clear of all persons or property. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. The aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N number) markings in accordance with 14 CFR part 45, subpart C. Markings must be as large as practical. The UAS must remain clear and give way to all manned aviation operations and activities at all times. The operator will obtain consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 50 feet of the flight operation. Additionally, the operator will obtain consent to film over private property from the property owner. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site. For the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply and will be adhered to. The operator must have a motion picture and televisions operations manual (MPTOM) as documented in this grant of exemption. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3 day notification may be waived with the concurrence of the FSDO. The Plan of Activities must include at least the following. Dates and times for all flights Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption Name and phone number of the person responsible for the on-scene operation of the UAS Make, model and serial or N-number of UAS to be used Name and certificate number of UAS PICs involved in the aerial filming A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming; a list of those who gave permission must be made available upon request Signature of exemption holder or representative A description of the flight activity, including maps or diagrams of any area, city, town, county and/or state over which filming will be conducted

Page 4Regulations From Which Exemption Is Requested: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates Given the size and limited operating area associated with the UAS to be utilized by Devor Productions, LLC, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt the UAS from the requirement for an Airworthiness Certificate, upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that a UAS operated without an Airworthiness Certificate, in a restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an Airworthiness Certificate without the restrictions and conditions proposed. 14 C.F.R. § 61.23(a) and (c): Medical Certificates Exemption #11221, #11284 and many others have provided that a U.S. driver’s license could be used in lieu of the medical certificate and provides an equivalent level of safety. 14 C.F.R § 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations & 14 C.F.R. § 61.315: Sport Pilot Limitations Exemption #11221, #11284 and many others have declared that there is an equivalent level of safety as the FAR’s by requiring the PIC to “hold either an airline transport, commercial, private, recreational or sport pilot certificate.” Likewise, Devor Productions, LLC is also performing commercial UAS work and is asking for the same restrictions which have been previously deemed to provide an equivalent level of safety as the prescribed regulations. 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve an equivalent level of safety of current operations by requiring all operations to be supervised by (at minimum) an individual holding private pilot’s license rather than requiring that individual to hold a commercial pilot’s license to operate a small UAS. Unlike conventional manned aircraft, a ground-based operator remotely controls a UAS. The operational area is limited, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a UAS are far lower from those associated with commercial operations contemplated by Part 61. Allowing operational control of a UAS by a private pilot exceeds the present level of safety sought by 14 C.F.R. § 61.113(a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, airspace, NOTAMS, TFR’s flight battery requirements, landing and take off distance and performance data before commencement of flight. Additionally, the UAS will be checked for security of attached components prior to every flight. 14 C.F.R. § 91.109: Flight Instruction Section 91.109 states, “No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” The proposed UAS will be operated utilizing computer assisted controls to maintain controlled flight, and the UAS is programmed to return to a level attitude and hover when the controls are returned to the neutral position. Because of these built-in safety features, dual control is not necessary in order to maintain an equivalent level of safety proposed by section 91.109 during training. All training will be conducted in a controlled environment as to not cause undue harm or damage to persons or property.

Page 514 C.F.R. § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. Because of the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude operations of the UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with section 91.119. 14 C.F.R. § 91.121: Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain altitude by reference to a altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting before departure.” As a UAS may not have a barometric altimeter, but instead reference a GPS altitude, an exemption is needed. The operator will achieve an equivalent level of safety, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151: Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning “ a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed - (1) During the day, to fly after that for at least 30 minutes...” The battery powering the proposed UAS provides approximately 22 minutes of powered flight. Therefore, the UAS cannot meet the 30 minute reserve requirement in 14 C.F.R. § 91.151. In lieu of this requirement the UAS flight will be terminated at approximately 25% remaining battery life or better. Devor Productions, LLC believes that an equivalent level of safety can be achieved by limiting flights to 25% of battery power. This restriction would be more than adequate to return the UAS to its pre-determined landing zone from anywhere in its limited operating range. Devor Productions, LLC is not seeking an exemption for night-time UAS operations. 14 C.F.R. § 91.405: Maintenance Inspections These regulations require that an aircraft operator or owner “shall have that 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....” and others shall inspect or maintain the aircraft in compliance with part 43. Given that these sections and part 43 apply only to aircraft with an air worthiness certificate, these sections will not apply to Devor Productions, LLC operations. Maintenance will be accomplished by the operator in accordance with the manufacturers recommended procedures. An equivalent level of safety will be achievedbecause the UAS is limited in size, will carry a small payload and operate only for limited periods of time. A preflight inspection will be performed prior to every flight to ensure no mechanical issues are present. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to flight and perform any required maintenance. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in a airworthy condition. 14 C.F.R. § 91.407: Operation After Maintenance Functional check flights will be conducted away from people or property after any maintenance has been accomplished on the UAS. The UAS may be returned to service once it has been determined to be safe for flight. 14 C.F.R. § 91.409: Inspections Due to the small size of the UAS that will be operated by Devor Productions, LLC and its limited components, we request that the UAS be exempt from regularly scheduled inspections. To meet an equivalent level of safety sought by 14 C.F.R. § 91.409, the UAS will be inspected prior to flight. Since the UAS will have limited

Page 6