August 27, 2015

Exemption No. 12628

Regulatory Docket No. FAA–2015–1447

Mr. Michael R. Monar

Monar Aero

3250 West Crystal Street

Unit 3

Chicago, IL 60651

Dear Mr. Monar:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 17, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Monar Aero (hereinafter petitioner or operator) for an exemption. The petitioner

requested to operate an unmanned aircraft system (UAS) to conduct closed-set filming of 

motion pictures, music videos, web videos, corporate videos, television programs and 

commercials, and still photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received one comment in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner are the Monar Aero X8 and Monar Aero V4.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1 and closed set motion picture and 

filming. The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Monar Aero is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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closed set motion picture and filming. This exemption is subject to the conditions and 

limitations listed below.

Conditions and Limitations

In this grant of exemption, Monar Aero is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Monar Aero X8 

and Monar Aero V4 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.

2. Operations for the purpose of closed-set motion picture and television filming 

are permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the 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.

6. All operations must utilize a visual observer (VO). The UA 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 or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
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documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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 a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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 authorized.

16. The UA 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 airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
6

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All 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 practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. 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.

28. 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 
7

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. 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:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. 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 and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 17, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

W. Building Ground Fl. Room W12­140

Washington, DC 20590

Monar Aero’s Exemption Request Pursuant to Section 333 of the FAA Reform Act of

2012 To Operate Unmanned Aircraft Systems for Aerial Photography and Filming

FAA Regulatory Docket

Name And Address of Petitioner

Monar Aero

Attn: Michael R. Monar

3250 W. Crystal St. #3

Chicago, IL 60651

917.971.9799

michael@monaraero.com
U.S. DOT

April 17, 2015

Page 2

I. Petition Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012,

Pub. L. No. 112­95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), Monar

Aero, (“Petitioner”) hereby petitions for exemptions from:

14 C.F.R. Part 21

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.103(b)(1)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151

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. 91.417(a)­(b).

The proposed exemptions, if granted, would allow Petitioner to operate small,

camera­mounted unmanned aircraft systems (“UAS”) weighing 55 pounds or less

including payload (i.e. camera, lens, remote head) for the purpose of closed­set filming of

motion pictures, music videos, web videos, corporate videos, television programs and

commercials, and still photography.

March 20, 2015

Page 2

The Petitioner’s UAS operations will take place only within closed and controlled,

“sterile” set conditions under the auspices of experienced and qualified UAS operators.

Monar Aero UAS, operating with no onboard crew and battery power, represent a
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April 17, 2015

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significant step forward in safety over larger traditional aircraft carrying crew and

flammable fuel. All operations by Monar Aero will be conducted under protocols set forth

in Petitioner’s Flight Operations and Procedures Manual (“FOPM”), the Motion Picture

and Television Flight Operation Manual (“MPTFOM), and any additional rules established

by the FAA specifically for UAS. Following the precedent of exemptions already granted

by the FAA, approval of Monar Aero’s petition will fulfill the mandate of Section 333 in

providing for safe civil UAS operations in the National Airspace System (“NAS”) and

serves the public interest. The Petitioner respectfully asks that the FAA grant the requested

exemptions without delay.

II. Background

A. Experience

Monar Aero’s crew of seasoned film industry professionals posses nearly

half a decade of experience in engineering, building, and operating UAS at a

non­commercial level. Their proven and ultra stable UAS platforms carry the latest

in feature film quality camera equipment such as the Red Dragon and Arri ALEXA

Mini. The Petitioner’s extensively tested lightweight UAS platforms can replace the

far more dangerous full size helicopters now engaged in aerial cinematic capture.

B. Aircraft and Equivalent Level of Safety

As set forth in the Monar Aero FOPM, the operation of UAS will meet or

exceed the current levels of safety attained by traditional aircraft engaged in

cinematic capture. In accord with the key considerations noted in The Reform Act:

1. The weight, size, speed and overall capabilities of the UAS

2. Whether the UAS will be operated near airports or populated areas

3. Whether the UAS will be operated by line of sight

the Petitioner will abide by the following guidelines:
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April 17, 2015

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● Monar Aero’s UAS will have a gross weight of not more than 55 pounds.

● UAS will be operated at a speed of no more than 50 knots.

● The minimum crew for UAS operations will consist of a Pilot In Charge

(“PIC”), Camera Operator (“CO”), and a Visual Observer (“VO”).

● Communication between PIC, Camera Operator and Visual Observer will be

facilitated by hands free two way radio.

● A safety meeting must be conducted prior to each day’s operations. All crew

working within the, “Security Perimeter” must attend to be briefed on the

planned operations.

● Flights will be performed at no more than 400 feet AGL.

● UAS will utilize a radio frequency spectrum for operation and control that

complies with Federal Communications Commission (“FCC”) requirements.

● UAS will not carry explosive materials or combustible fuels

● UAS flights will be performed within line of sight of the PIC and the Visual

Observer

● The UAS crew will consist of at least one FAA licensed airman with a

private pilot’s license and third class medical certificate.

● UAS flights will last only 5­25 minutes each.

● UAS will land before battery levels go below 25%. Should battery levels

drop to 25% unexpectedly, the Monar Aero UAS has programmed failsafe

protocol whereby it will perform a pre­programmed, predictable, automated

flight maneuver and return to a predetermined landing site within the defined

“Security Perimeter.”

● UAS operations will take place only within controlled and pre­determined

“Security Perimeters.”

● UAS are equipped with redundant safety mechanisms allowing them to

operate safely after experiencing Command And Control (“C2”) link failures.

If a C2 link event occurs, including the loss of ground communications

and/or the loss of a GPS signal, the Monar Aero UAS have the ability to

perform a pre­programmed, predictable, automated flight maneuver and
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April 17, 2015

Page 5

return to a predetermined landing site within the defined “Security

Perimeter.”

● Telemetry data including battery level, speed, altitude, GPS satellite lock,

and flight mode will downlink from the UAS to a ground­based on­screen

display

● Monar Aero will obtain consent from all persons involved in the aerial

filming scenario. Persons not involved in filming will not be allowed within

100 feet of the operation.

● All required permissions and permits will be obtained from territorial, state,

county, or city jurisdictions, including local law enforcement, fire or other

appropriate government agencies.

● The PIC and VO must be trained in UAS operation, and the particular UAS

craft to be operated, as per the Monar Aero FOPM.

● In the event that the, “Security Perimeter” is breached and/or potential safety

breaches are imminent, operations will be breached following protocol

outlined in the FOPM.

III. Specific Exemptions Requested by Monar Aero Under Section 333.

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 Monar Aero’s UAS permits exemption from Part 21

because Monar Aero’s UAS meet 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 UASs from the airworthiness certificate
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April 17, 2015

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requirement in consideration of the weight, size, speed, maneuverability and proximity to U.S.

areas such as airports and dense populations. Monar Aero’s UAS meet or exceed each of these

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, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual at the flight operations

center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Monar Aero’s

UAS utilize electronic global positioning systems, accelerometers and multiple integrated

gyroscopes to provide spatial coordination.

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 such certifications and registrations at the Monar

Aero’s flight operations center.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Monar Aero UAS are unmanned and relatively small, without a traditional cabin or

fuselage on which to place registration markings. Petitioner’s UAS will be identified by

individual serial number, registered in accordance with 14 C.F.R. Part 47, and have identification

(N­Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as

large as practicable.
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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. Monar Aero UAS do not carry pilots or passengers and as such can achieve an U.S.

equivalent level of safety as achieved by current Regulations. Unlike conventional manned

aircraft, all of the Petitioner’s UAS operations are controlled from the ground and held within

cordoned off and controlled, “Security Perimeters.” In addition to possessing a private pilots

license, the PIC will have attained the necessary remote piloting skills and knowledge as outlined

in the Monar Aero FOPM. Consequently, the safety risks of operating a relatively small,

unmanned Monar Aero UAS are significantly less than those associated with operating

conventional manned commercial operations. Thus, allowing operation of a Monar Aero

UAS by a private pilot as the PIC exceeds the present level of safety sought by 14 C.F.R.

§61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. In pertinent part,

it states that:

“(d) Helicopters, powered parachutes, and weight­shift­control aircraft.​If the

operation is conducted without hazard to persons or property on the surface­”

Monar Aero UAS will only operate within an established, “Security Perimeter” below 400 AGL,

providing an equal or greater level of safety provided in relation to minimum safe altitudes. In

contrast to conventional helicopters, Petitioner’s UAS carry no passengers, pilots, or explosive

fuels, thus an equivalent or greater level of safety will be realized.

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

Inspections.
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April 17, 2015

Page 8

These 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 apply only to aircraft with an airworthiness certificate, they will not apply to

Monar Aero operations should its exemption be granted. As outlined in the FOPM, Monar Aero

conducts its own strict maintenance regimen. The operator will be responsible for inspections

and any maintenance necessary. As provided for in the FOPM, the operator will fulfill all

system checks prior to flight to verify that the UAS is in good working order. Any discrepancies

will be repaired and noted in the Maintenance Log. Should discrepancies arise

during an operation, the UAS will be grounded immediately in accordance with mission abort

protocol prescribed in the FOPM. An equivalent level of safety will be achieved because the

UASs operate no higher than 400 AGL, are subject to extensive maintenance regimens, weigh

less than 55 pounds, are more maneuverable than conventional manned aircraft, and can easily

be landed should mechanical issues arise.

IV. Summary

Monar Aero 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 operate commercially its fleet of small unmanned vehicles and lightweight

unmanned vehicles for the purpose of closed­set filming of motion pictures, music videos, web

videos, corporate videos, television programs and commercials, and still photography.

As already established by previous UAS exemptions granted by the FAA, commercial

use of UAS by the film industry will serve to increase the level of safety afforded to aerial

cinematic capture. UASs reduce risk by eliminating the need for manned aircraft weighing

thousands of pounds and carrying large amounts of explosive fuel. Monar Aero UASs, weighing

less than 55 pounds, operating under battery power and within strict, “Security Perimeters”

mitigate risk to human life. These factors justify Monar Aero’s petition for exemption and
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April 17, 2015

Page 9

satisfy the criteria provided in section 333 of the Reform Act of 2012. Monar Aero will comply

with the same conditions and limitations as provided in numerous section 333 exemptions

granted recently for closed set filming and other purposes. Accordingly, we respectfully ask the

FAA to grant this petition in summary fashion, and obviate Federal Register publication and

public comment.

Kind Regards,

Michael R. Monar