Michael	Glenn	Weddle

Counsel	for	RemotelyFilmed 602	Wyngate	Drive Frederick,	MD	21701 September	16,	2015 United	States	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Avenue.,	SE West	building	Groud	Floor	Room	W12

- 140 Washington,	DC	20590 Re:			Exemption	Request	Pursuant	To	Section	333	of	the	FAA	Reform	Act	of	2012 and	Part	11	of	the	Federal	Aviation	Regulations.
Dear	Sir	or	Madam: I	represent	RemotelyFilmed;	a	Maryland	based	Videography	Company.	I	am	writing pursua nt	to	the	FAA	Modernization	and	Reform	Act	of	2012	and	the	petition	for exemption	procedures	directed	in	14	C.F.R.	11,	to	request	that	RemotelyFilmed,	an owner	and	operator	of	unmanned	aircraft,	be	exempted	from	the	Federal	Aviation Regulations	listed	belo w	so	that	RemotelyFilmed	may	operate	its	unmanned	aircraft commercially	in	airspace	regulated	by	the	Federal	Aviation	Administration. RemotelyFilmed	wishes	to	provide	aerial	videography	and	photography	services through	the	use	of	small

- unmanned	aircraft and	lightweight	UASs	primarily	in	the motion	picture	industry as	well	as	aerial	data	collection .	RemotelyFilmed’s	UASs	are some	of	the	most	advanced	remote	control	aircraft	available	for	these	purposes. RemotelyFilmed seeks	permission	to	fly	its	UASs	commercially	within	the	United States	to	capture	aerial	videography	and	photography. RemotelyFilmed’s	exemption	request	would	permit	its	operation	of	lightweight, unmanned	(piloted	by	remote	control)	aircraft	and	UASs (D JI	Phantom	2) in controlled	and	limited	airspace.	Each	of	RemotelyFilmed’s	UAS	pilots	has	undergone maintenance	and	flight	training	from	a	UAS	training	program. Granting	RemotelyFilmed's	request	will	comport	with	the	Secretary	of Transportation’s	(through the	FAA	Administrator)	responsibilities	to	integrate	UASs into	the	national	airspace	system,	consistent	with	future	"...requirements	for	the	safe operation	of	such	aircraft	systems	[UASs]	in	the	national	airspace	system"	under Section	333(c)	of	the	Reform Act.	RemotelyFilmed	will	conduct	its	operations	in compliance	with	the	protocols	described	herein	or	as	otherwise	established	by	the FAA. 2For	the	reasons	stated	below,	RemotelyFilmed	respectfully	requests	the	FAA	grant

an	exemption	allowing	it	to	operate lightweight,	remote	controlled	UASs.	Specific Sections	of	the	Title	14	of	the	Code	of	Frderal	Regulations	from	which RemotelyFilmed	Requests	Exemption	listed	below: 14	C.F.R.	21,	subpart	H; 14	C.F.R.	§45.23(b); 14	C.F.R.	§61.113(a)	and	(b);	14	C.F.R.	§9 1.9(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.	§407(a)(1);
14	C.F.R. §409(a)(2);	and	14	C.F.R.	§417(a)	and	(b). RemotelyFilmed	submits	this	applications	in	accordance	with	§§	331

- 334	of	the Reform	Act	seeking	relief	from	currently	applicable	FAR's that	would prevent RemotelyFilmed's	contemplated	commercial	cinematic,	photog raphic	and	other flight	operations	within	the	national	airspace	system.	Section	332	of	the	Reform	Act provides	for	such	integration	of	civil	unmanned	aircraft	systems	into	our	national airspace	system	in	the	public	interest. RemotelyFilmed’s lightweight	U ASs	meet	the	standards	of	"small	unmanned aircraft"	as	defined	in	Section	331(6);	the	integration	of	lightweight	UASs	of	the	type operated	by	RemotelyFilmed	is	expressly	contemplated	by	the	Reform	Act. Importantly,	client	demands	and	similar	plans	of	compe titors	to	provide	this	type	of service	require	RemotelyFIlmed	be	able	to	operate	its	lightweight	UASs	as	quickly	as possible,	and	likely	prior	to	FAA	promulgation	of	final	rules	governing	such operations .	The	flying	of	UASs	is	becoming	more	popular	and	wil l	be	of	great	benefit both	to	the	community	and	to	the	economy. The	Reform	Act3	guides	the	Secretary	in	determining	the	types	of	UASs	that	may operate	safely	in	our	national	airspace	system.	Considerations	include: •	The	weight,	size,	speed	and	overall	ca pabilities	of	the	UAS;•	Whether	the	UAS	will	be	operated	near	airports	or	populated	areas;	and

•	Whether	the	UAS	will	be	operated	by	line	of	sight. RemotelyFilmed’s	plans	regarding	these	factors	support	an	exemption. RemotelyFilmed	's	UASs	utilize	four	to eight	(the	model	intended	to	be	used	most often	is	the	eight

- propeller	model)	counter

- rotating	propellers	for	extreme	balance, control	and	stability.	Each DJI	Phantom	2 weighs	less	than	55	pounds,	including cinematic	or	other	equipment.	Each	of	RemotelyFi lmed	's	small

- unmanned	aircraft is	designed	to	primarily	hover	in	place	and	operate	at	less	than	a	50

- knot	maximum speed.	They	are	capable	of	vertical	and	horizontal	operations	but	operate	only within	the	line	of	sight	of	the	remote	control	pilot. Utilizin g	battery	power	and	not combustible	fuels,	flights	generally	last	less	than	twenty	minutes.	RemotelyFilmed will	not	operate	its	UASs	with	less	than	twenty

- five	percent	(25%)	battery	capacity. Safety	systems	in	place	include	a	GPS	mode	that	allows	RemotelyF ilmed	's	UASs	to return	to	a	home	safety	point	if	communications	are	lost. RemotelyFilmed will not operate its UASs near airports

... and Remotel yFi lmed will not operate their UAS over populated areas, unless such area (i) is a private set, (ii) has been sectioned off for closed

- set operations, and/or (iii) is under the control of RemotelyFilmed clients. Accordingly, All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
RemotelyFilmed	's	operation	of	its	fleet	of	small

- unmanned	aircraft	will	not	"create a	hazard	to	users	of	the	national	a irspace	system	or	the	public."4	Given	the	small size	and	weight	of	RemotelyFilmed	's	UASs,	which	will	be	operated	only	in	closed	off and	well

- controlled	areas,	RemotelyFilmed	's	UASs	fall	within	Congress’s contemplated	safety	zone	when	it	promulgated	the	R eform	Act	and	the corresponding	directive	to	integrate	UASs	into	the	national	airspace	system. RemotelyFilmed	's	UASs	do	not	pose	any	threat	to	the	general	public	or	national security. Granting	RemotelyFilmed	's	exemption	request	furthers	the	public	intere st. Congress	has	pronounced	through	the	Reform	Act	that	it	is	in	the	public’s	interest	to integrate	commercially	flown	UASs	into	the	national	airspace	system.	Further,	the public	has	an	interest	in	reducing	the	danger	and	emission	associated	with	current a erial	cinematic	capture	methods,	namely,	full	size	helicopters.	RemotelyFilmed	's UASs	are	battery	powered	and	create	no	emissions.	There	is	no	fuel	to	ignite	and explode	if	a	RemotelyFilmed	UAS	should	crash.	The	impact	of	RemotelyFilmed	's lightweight	UAS s	is	far	less	than	a	full	size	helicopter.	Minimizing	ecological	furthers the	public’s	interest	and	potential	crash	impacts	by	permitting	motion	picture capture	through	RemotelyFilmed	's	lightweight	UASs.Congress	mandated	the	integration	of	UASs	into	our national	airspace	system,	in

part,	to	achieve	the	societal	benefits	of	this	developing	UAS	technology,	with appropriate	safety	and	related	regulatory	guidance	from	the	FAA.	Permitting RemotelyFilmed	to	operate	its	UASs	is	consistent	with	these	goals.
RemotelyFilmed	's	exemption	will	not	adversely	affect	safety.	Permitting RemotelyFilmed	to	offer	aerial	videography	and	photography	services	without	the use	of	full	size	aircraft	will	decrease	the	overall	risk to	the	public	RemotelyFilmed’s	approach	is	safer	a nd	superior	to	current	aerial motion	picture	capture	techniques: •	RemotelyFilmed	's	UASs	weigh	less	than	55	pounds	(including	the	mounted camera); •	RemotelyFilmed	will	only	operate	its	UASs	below	400	feet; •	RemotelyFilmed‘s	UASs	will	only	operate	for	fl ights	lasting	less	than	20	minutes; •	RemotelyFilmed	will	land	its	UASs	when	they	reach 25%	battery	power ; •	RemotelyFilmed‘s	remote	control	pilots	operate	RemotelyFilmed	‘sUASs	by	line	of sight; •	RemotelyFilmed‘s remote	control	pilots	have	video	backup	should	they	somehow lose	sight	of	the UAS; •	RemotelyFilmed will	be	flying	with	an	experienced	UAS	pilot •	RemotelyFilmed	‘s	UASs	have	GPS	flight	modes	whereby	they	return	to	a	safe home	location	if communication	wi th	the	remote	control	pilot	is	lost; •	RemotelyFilmed	employs	FAA	licensed	private	pilot(s)	and	conducts	a	regimented training	and continuing	education	program; •	RemotelyFilmed	will	only	operate	in	quarantined	areas	that	are	strictly	controlled, and	away from airports	and	populated	areas; •	RemotelyFilmed	pilots	will	always	conduct	extensive	preflight	safety	briefings with	all	persons	who will	be	allowed	in	the	flight	operations	area,	which	includes	planning	and	briefings for contingency	emergency	procedur es; •	RemotelyFilmed	will	always	obtain	all	necessary	permissions	and	permits	prior	to operation;	and, •	RemotelyFilmed	has	procedures	to	abort	flights	in	the	event	of	safety	breaches	or potential danger. RemotelyFilmed	‘s	safety	protocols	provide	a	level of	safety	at	least	equal	to	existing rules,	and	in	most	instances,	greater	than	existing	rules.	It	is	important	to	note	that absent	the	integration	of	commercial	UASs	into	our	national	airspace	system, helicopters	are	the	primary	means	of	aerial	videography	and	photography.	While the	safety	record	of	such	helicopters	is	strong,	it	is	far	safer	to	operate	a	battery powered	lightweight	UAS.	First,	the	potential	loss	of	life	is	diminished	because	UASscarry	no	people	on	board,	and	RemotelyFilmed	only	operates them	in	closed	set

operations	away	from	mass	populations.	Second,	there	is	no	fuel	on	board	a	UAS	and thus	the	potential	for	fire	or	explosions	is	greatly	diminished.	Third,	the	small	size and	maneuverability	of	RemotelyFilmed’s	UASs	allow	the	remote	contr ol	pilots	to avoid	hazards.	Accordingly,	RemotelyFilmed’s	UASs	will	operate	at	or	above	current safety	levels.	Lastly,	RemotelyFilmed’s	proposed	operations	would	comply	with	the applicable	provisions	of	Proposed	Part	107	to	Title	14,	and	therefore	fit	with in	the restrictions	currently	contemplated	by	the	FAA	with	respect	to	the	commercial operation	of	UASs. Summary
RemotelyFIlmed	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)	and	(b) ;	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);	a nd,	14	C.F.R. §§91.417(a)	and	(b),	to	commercially	operate	its	fleet	of	UASs	in motion	picture, televisio n, photography	operations ,	and	aerial	data	collection

. Granting	RemotelyFilmed's	request	for	exemption	will	reduce	current	risk	levels and	thereby	enha nce	safety.	Currently,	videography	and	photography	image	capture relies	primarily	on	the	use	of	larger	aircraft	running	on	combustible	fuel. RemotelyFimed's	craft	do	not	contain	potentially	explosive	fuel,	are	smaller,	lighter and	more	maneuverable	than	co nventional	aircraft	used	for	these	purposes. Further,	RemotelyFilmed	will	operate	at	lower	altitudes	and	in	controlled	airspace. RemotelyFilmed's	UASs	carry	only	a	camera,	and	therefore	in	a	UAS	incident	the likelihood	of	death	or	serious	bodily	injury	is significantly	limited.	RemotelyFIlmed's operation	of	its	UASs,	weighing	less	than	55	pounds	and	traveling	at	speeds	lower than	50	knots	in	closed	off	areas	will	provide	at	least	an	equivalent	level	of	safety	as that	achieved	under	current	FARs. Important	D JI	Documents: http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf http://download.dji

innovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_ Guidelines.pdf http://download.dji

innovations.com/downloads/phantom_2/en/Phantom_2_Release_Notes_en.pdfAccordingly,	RemotelyFilmed respectfully	requests	that	the	FAA	grant	its	exemption

request	set	forth	herein.	Respectfully	submitted, President,	RemotelyFilmed