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	

pursuant	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	below	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 (DJI	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.2	
For	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.	§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.	§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,	photographic	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	UASs	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	competitors	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	will	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	capabilities	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	RemotelyFilmed	'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. Utilizing	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	RemotelyFilmed	's	UASs	to	

return	to	a	home	safety	point	if	communications	are	lost.

RemotelyFilmed will not operate its UASs near airports... and RemotelyFilmed 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	airspace	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	Reform	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	interest.	

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	

aerial	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	UASs	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	and	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	flights	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	with	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	procedures;

•	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	UASs	
carry	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	control	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	within	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);	and,	14	C.F.R.	

§§91.417(a)	and	(b),	to	commercially	operate	its	fleet	of	UASs	in	motion	picture,	

television,	photography	operations,	and	aerial	data	collection.

Granting	RemotelyFilmed's	request	for	exemption	will	reduce	current	risk	levels	

and	thereby	enhance	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	conventional	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	DJI	Documents:

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

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety_

Guidelines.pdf

http://download.djiinnovations.com/downloads/phantom_2/en/Phantom_2_Release_Notes_en.pdf
Accordingly,	RemotelyFilmed respectfully	requests	that	the	FAA	grant	its	exemption	

request	set	forth	herein.	Respectfully	submitted,

President,	RemotelyFilmed