1

Miracle Films, Inc.

39 Devonshire Drive

Conroe, Texas 77304

713 248-4394

genem@miraclefilms.net

United States of America 

Department of Transportation 

Federal Aviation Administration 

Washington DC 

Basis for Petition: 

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 91.119(a)(b), 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(ap 

(1); 91.409(a) (2); 91.417(a)&(b); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(2); and 14 C.F.R. 

417(a)&(b) 

Dear Sir or Madam:

We are writing pursuant to the FAA Modernization and Reform Act of 20121 (the "Reform Act") 

and the procedures contained in 14 C.F.R. 11, to request that Miracle Films, Inc., an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations 

("FARs") listed below so that Miracle Films, Inc., may operate its small unmanned aircraft / 

lightweight unmanned aircraft systems, such as Walkera X-830S, Walkera Scout, DJI Phantom 

3 and Inspire ("UAS"), commercially in airspace regulated by the Federal Aviation 

Administration ("FAA"); as long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the applicant are drawn from 

Order 8900.1 CHG 0, Volume 3, Chapter 8-lssue a Certificate of Waiver for Motion Picture and 

Television Filming.

As identified and described herein, William McMahon, and his company Miracle Films, 

Inc., is an experienced, recognized veteran in the broadcast and television production industry. 

Mr. McMahon has been producing high end commercial and industrial communications for 

global clients for over twenty-five (25) years. In the course of that work, Mr. McMahon has 

logged many hours of aerial photography in both fixed wing aircraft, and helicopters, in aircraft 

such as the Bell 206L & 412, AS-350, BK-117, & Sikorsky S-76 & S-92. Mr. McMahon has also 

been an avid radio control model flyer for over nine (9) years. Mr. McMahon has had extensive 

experience producing communications in over 43 countries, in the oil and gas and heavy 

construction industries.
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Miracle Films, Inc. exemption request would permit its operation of lightweight, unmanned 

(remotely controlled in line of sight) UASs, in tightly controlled and limited airspace. 

Predetermined, specifically marked areas of operation, cordoned off locations and 

corresponding enhancements to current safety confrols will allow Miracle Films, Inc. to operate 

within current safety parameters and new ones being implemented. As identified, similar 

lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

no safety plan, and no safety controls in place. Miracle Films, Inc. has in place, and will follow 

its UAS Pre-Flight Safety Checks, Flight Protocols and Controls for safe operation so as to 

avoid and prevent hazards to the public. 

Granting Miracle Films, Inc. request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UASs into the national airspace system, 

but to "...establish requirements for the safe operation of such aircraft systems [UASs] in the 

national airspace system" under Section 333(c) of the Reform Act. Further, Miracle Films, Inc. 

will conduct its operations in compliance with the protocols described herein or as otherwise 

established by the FAA.

Miracle Films, Inc. respectfully requests the grant of an exemption allowing it to 

operate lightweight, remote controlled UAS’s.

The Specific Sections of Title 14 of the Code of Federal Regulations, Miracle Films, Inc. 

Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b)•, 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 

(a) 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation

Regulations from 14 C.F.R. 45.23(b) CFR Part 21;14 CFR 61.113 (a) & (b); 91.7(a); 

91.9(b)(2); 91.103(b); 91.109;91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 

91.407(a)(1); 91.409 (a)(2); 91.417 (a) & (b). 

With this exemption Miracle Films, Inc. is requesting permission to fly a UAS for 

commercial purpose of conducting aerial video and photography for advertising, architectural,

hospitality, real estate, special events, motion picture and TV production, agriculture and 

infrastructure inspection and landscape over certain areas of the United States. 

The UASs that will be operated by Miracle Films, Inc. will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
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The Extent of Relief Miracle Films, Inc. Seeks and the Reason It Seeks Such Relief:

Miracle Films, Inc. submits this application in accordance with the Reform Act, 112 PL. 95 

§§ 331-334, seeking relief from any currently applicable FARs operating to prevent

Miracle Films, Inc. contemplated commercial cinematic, research and other flight operations 

within the national airspace system. Miracle Films, Inc. lightweight UASs meet the definition of 

"small unmanned aircraft" as defined in Section 331 and therefore the integration of Miracle 

Films, Inc. lightweight UASs are expressly contemplated by the Reform Act. Miracle Films, Inc. 

would like to operate its lightweight UASs prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft.

Petitioner, Miracle Films, Inc., pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the UASs in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

unmanned aircraft and its operation, Miracle Films, Inc. operation of UASs meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Miracle Films, Inc. requests exemption from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance 

that only apply to aircraft with an airworthiness certificate. 

 Miracle Films, Inc. offers that the requested relief is proper since an equivalent level of 

safety will be ensured. Miracle Films, Inc. will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Maintenance Logs, and 

Instruction Manual). Furthermore, Miracle Films, Inc. will document and maintain all 

maintenance records for the UASs. 

Exemption from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations:

 Pilot in command, is requested by Miracle Films, Inc. to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman 

medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the UASs in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Miracle Films, Inc. seeks exemption from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the UASs do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Miracle Films, Inc. presents that he will ensure that the 

UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Maintenance Log, Instruction Manual), and that 

the aircraft are in a condition for safe flight. 
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Miracle Films, Inc. also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the UAS will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which downlinks from 

the UAS to the GCS for active monitoring of the flight path. This altitude information, combined 

with Miracle Films, Inc. operation of the UASs within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Miracle Films, Inc. seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions.

 Miracle Films, Inc. presents that safety will not be affected by operation of the UAS during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with 

enough battery power to fly for a total duration of approximately 20 minutes and assuming 

normal cruising speed, after returning to the take off/landing point, and will not fly with a battery 

power containing less than twenty-five percent..

In accordance with 14 C.F.R. § 11.81, Miracle Films, Inc. provides the following 

information in support of its petition for exemption:

Name And Address Of The Petitioner

Miracle Films, Inc.

William McMahon III

39 Devonshire Drive

Conroe, Texas 77304

genem@miraclefilms.net

713 248-4394

The Specific Sections Of 14 C.F.R. From Which Miracle Films, Inc. Seeks Exemption

1. Miracle Films, Inc. Seeks Exemption From The Requirements Of Section 61.113(a)&(b)

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Miracle Films, Inc. Seeks Exemption From The Requirements Of Section 91.7(a)

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 
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3. Miracle Films, Inc. Seeks Exemption From The Requirements Of Section 91.121

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure. 

4. Miracle Films, Inc. Seeks Exemption From The Requirements Of Section 91.151(b)

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. 

5. Miracle Films, Inc. Seeks Exemption From The Requirement Of Section 91.405(a)

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) 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[.] 

6. Miracle Films, Inc. Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter [.] 

7. Miracle Films, Inc. Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 

And 91.409(a)(2)

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. 
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8. Miracle Films, Inc. Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b)

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service. 
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Scope of Exemption Miracle Films, Inc. Seeks and Reasoning of Proposed Exemption 

1. Extent Of Relief Miracle Films, Inc. Seeks And The Miracle Films, Inc. Seeks Relief 

From Section 61.113(a) And (b)

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This exemption is requested since the limitations set forth in Section 61.113(a) and (b) state that 

a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Miracle Films, Inc. presents that an equivalent level of safety will be maintained because no PIC 

will be allowed to operate the unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate UAS in a manner consistent 

with the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures.

Further, Miracle Films, Inc. submits that all flights of the UASs, conducted by the PIC pursuant 

to the grant of this Petition: (1) will be related to Miracle Films, Inc. business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief Miracle Films, Inc. Seeks And The Reason Miracle Films, Inc. Seeks 

Relief From Section 91.7(a)

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the scope

required to allow Miracle Films, Inc. to determine that the UASs are in airworthy condition prior 

to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

Maintenance Log, Instruction Manual). 

Miracle Films, Inc. seeks the requested exemption because the UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Miracle 

Films, Inc. will ensure that the UASs are in airworthy condition based upon its compliance with 

the operating documents (i.e., Maintenance Log, Instruction Manual) prior to every flight, and 

further, determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below.

3. Extent Of Relief Miracle Films, Inc. Seeks And The Reason Miracle Films, Inc. Seeks 

Relief From Section 91.121

Exemption from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the UASs, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the PIC

at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Miracle Films, Inc. seeks the requested reprieve because the UASs altimeter may be set 

on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight. 
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Considering the limited altitude of the proposed operations, exemption from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. An equivalent level of safety will be maintained since the UAS are equipped with GPS 

equipment, which automatically ensures that a ground level setting will be established prior to 

each flight, and provides the PIC with altitude information of the UA on the heads-up display of 

the GCS. 

4. Extent Of Relief Miracle Films, Inc. Seeks And The Reason Miracle Films, Inc. Seeks

Exemption From Section 91.151(b)

Exemption from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 20 minutes to the first point of intended landing and will not fly with a battery power 

containing less than twenty-five percent. Miracle Films, Inc. seeks the requested relief because 

without an exemption from Section 91.151(b), the flight time duration of the battery powered 

UAS will severely constrain the practicality of any aerial video or still photo flight operations that 

Miracle Films, Inc. proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the UASs, the operating 

documents, and Miracle Films, Inc. proposed operating limitations, ensure that Miracle Films, 

Inc. will safely operate the battery powered UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 20 minutes to the first point of intended landing.

5. Extent Of Exemption Miracle Films, Inc. Seeks And The Reason Miracle Films, Inc.

Seeks Exemption From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b)

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Miracle Films, Inc. requests exemption from these 

Sections because the UASs do not require airworthiness certificates. As set forth more fully 

below, the UASs meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Therefore, Miracle Films, Inc. will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., Maintenance Log, 

Instruction Manuals). Furthermore, Miracle Films, Inc. will document and maintain all 

maintenance records for the UASs. 

Granting Miracle Films, Inc. Request Would be in the Public Interest

Granting the present petition will allow Miracle Films, Inc. to safely, efficiently, and economically 

perform aerial video and photography, motion picture and television sets, construction sites, real 

estate, and landscape photography over certain areas of the United States. 

Additionally, use of the UASs will reduce pollution, decrease congestion of the NAS above 500 

feet, and provide benefits to the economy with the growth of Miracle Films, Inc.. Notably, the 

benefits of Miracle Films, Inc. proposed operation of the UASs would be done without violating

any privacy issues. 
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1. The Public Will Benefit From Decreased Congestion Of The NAS

The UAS are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Additionally, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The UAS do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UASs

Conducting aerial photography & videography with the UASs, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power and 

electric motors, the UASs produce no air pollution, and are an environmentally conscious 

alternative to the customary cabin class, internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of 

aviation fuel. The UAS, while reducing the carbon footprint of aerial assignments, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather 

than an internal combustion engine. 

By using the UASs to perform aerial videography and photography, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the 

lack of flight crew members located onboard the aircraft, the has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The UASs Will 

Benefit The Economy

In addition to being safe and efficient, the UASs are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the UASs will allow 

United States based companies, like Miracle Films, Inc., to remain competitive and contribute to 

growth of the U.S. economy. Operating the battery powered UASs is an evolving technology 

that allows companies greater operational flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the UASs, companies such as Miracle Films, Inc., can remain competitive and 

profitable, and therefore, provide greater job stability to potential employees and contractors, 

which will ultimately contribute to growth of the economy. Improved financial performance of 

such companies, through commercial use of the UASs, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues.
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4. General Public Privacy Concerns

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Miracle Films, Inc. proposed operation of the UASs will not implicate any privacy issues. 

Specifically, the UASs will be operated only in compliance with operating documents (i.e., 

Maintenance Log, and Instruction Manuals) which requires property owner involvement as well 

as local law enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. 

Reasons Why Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a 

Level of Safety At Least Equal To Existing Rule:

Miracle Films, Inc. exemption will not adversely affect safety. Miracle Films, Inc. submits the 

following representations of enhancements to current aerial motion picture capture techniques:

 Miracle Films, Inc. UASs weigh less than 55 pounds complete;

 Miracle Films, Inc. only operates its UASs below 400 feet;

 Miracle Films, Inc. UASs only operate for 5-25 minutes per flight;

 Miracle Films, Inc. lands its UASs when they reach 25% battery power;

 Miracle Films, Inc. remote control pilots operate Miracle Films, Inc. UASs by line of sight;

 Miracle Films, Inc. remote control pilots have video backup should they somehow lose 

sight of the UAS;

 Miracle Films, Inc. staffs each flight with a remote control pilot, and spotter;

 Miracle Films, Inc. UASs have GPS flight modes and are designed for automatic return 

to home point in the event of loss of the control link, whereby they hover and then slowly 

land if communication with the remote confrol pilot is lost or battery power is below 25%;

 Miracle Films, Inc. only operates in secured areas that are sfrictly controlled, are away 

from airports and populated areas;

 Miracle Films, Inc. conducts extensive briefings prior to flight, during which safety carries 

primary importance;

 always obtains all necessary permissions and permits prior to operation; and, Miracle 

Films, Inc. has procedures in place to abort flights in the event of safety breaches or 

potential danger.

Miracle Films, Inc. provides a level of safety at least equal to existing rules, and in nearly every 

instance, 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 

motion picture capture. While the safety record of such helicopters is remarkably astounding, 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 Miracle Films, Inc. only operates them 

in specific areas 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 extreme 

maneuverability of Miracle Films, Inc. UASs allow our remote control pilots to avoid hazards. 

Lastly, given their small size and weight, even when close enough to capture amazing images, 

Miracle Films, Inc. UASs need not be so close to the objects they are focused on. Accordingly, 

Miracle Films, Inc. UASs have operated and will continue to operate at and above current safety 

levels.
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A Summary the FAA May Publish in the Federal Register:

In summary, Miracle Films, Inc. 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. § 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 (a)(b); 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 commercially operate Miracle Films, Inc. UAS in community awareness, 

real estate operations, filmmaking, agricultural and industrial mapping for various industries and 

to develop economic platforms for small business. Currently all of these activities rely primarily 

on the use of larger aircraft running on combustible fuel, posing potential risk to the public. 

Granting Miracle Films, Inc. request for exemption will reduce current risk levels and thereby 

enhance safety. Miracle Films, Inc. will operate at lower altitudes and in controlled airspace 

eliminating potential public risk flying to and from established airfields. 

Accordingly; Miracle Films, Inc. respectfully request that the FAA grant this exemption request. 

Respectfully Submitted; 

December 14, 2015 

William McMahon, President

Miracle Films, Inc.

39 Devonshire Drive

Conroe, Texas 77304

713 248-4394

genem@miraclefilms.net