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); a nd 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 belo w so that Miracle Films, Inc. , may operate its small unmanned aircraft / lightweight unmanned aircraft systems

, such as Walkera X

- 830S, Walkera S cout, 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 FA A 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 identif ied 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 rad io 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.2

Miracle Films, Inc. exemption request would permit its operation of lightweigh t, 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 amat eurs with no flight experience, no safety plan , and no safety controls in place. Miracle Films, Inc. has in place

, and will fo llow 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 com ports 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 airsp ace 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 UA S 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 UAS s 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

.3

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 fl ight operations within the national airspace system. Miracle Fi lms, Inc. lightwe ight 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 lig htweight 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 commercial ly operate the UAS s 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 UAS s meets the
conditions of FMRA Section 333 a nd 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 fo rth 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 UAS s using the methods, techniques, and practices prescribed in the operating documents (i.e., Maintenance Log s , and Instruction Manual). Furthermore, Miracle Films, Inc. will document and maintain all
maintenance records for the UAS s.

Exemption from certain requirements of Section 61.113(a) and (b), entitled Private pi lot 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 demon strated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the UAS s in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining a ppropriate distances from people, vessels, vehicles and structures.

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

airworthiness

, because the UAS s 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
UAS s are in an airworthy condition, prior to every flight , by determining that the UAS s are in compliance with the operating documents (i.e., Maintenance Log, Instruction Manual), and that the aircraft are in a condition for safe flight.4

Miracle Films, Inc. also seeks an exe mption 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 UA S to the GCS for active monitoring of the flight path. This altitude information, combined

with Miracle Films, I nc. operation of the UAS s within visual line of sight, at or below 4 00 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 dayli ght 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 th e 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

. Mi racle Films, Inc. Seeks Exemption From The Requirements Of Section 6 1.113(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 privat e 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 compensati on or hire.

2. Miracle Films, Inc. Seeks Exemption From The Requirements Of Sect ion 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.5

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 Re qu irements 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 R equirement 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.6

8. Miracle Films, Inc. Seeks Exemption From The Requirements Of S ections 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, a nd 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 cur rent 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 safe ty 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 prescri bed 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 speci fied 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

wi th 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.7

Scope of Exemption Miracle Films, Inc. Seeks a nd 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 busin ess 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 descr ibed 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 UAS s, 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. Se eks 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 Film s, Inc. to determine that the UAS s 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 b ecause the UAS s 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 UAS s 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 i n the conditions and

limitations below.

3. Extent Of Relief Miracle Films, Inc. Seeks And The Reason Miracle Films, Inc. Seeks
Relief From Sect ion 91.121 Exemption from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the UAS s, 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 UAS s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.8

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. A n equivalent level of safety will be maintained since the UAS are equipped with GPS equipment, which auto matically 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 UAS s, 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 UAS s do not require airworthiness certificates. As set forth more fully below, the UAS s meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Therefore

, Miracle Films, Inc. will use tr ained technicians to perform maintenance, alterations, or preventive maintenance on the UAS s using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Maintenance Log,

Instruction Man ual s ). Furthermore, Miracle Film s, Inc. will document and maintain all
maintenance records for the UAS s.

Granting Miracle Films, Inc. R equest W ould be in the P ublic Interest

Granting the present p etition 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 UAS s 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 Fi lms, Inc. proposed operation of the UAS s would be done without violating any privacy issues.9

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 t he 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 numb er 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, arriv al, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UAS s

Conducting aerial photography & videography with the UAS s, 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 UAS s 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 burni ng 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 UAS s 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 trad itional 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 UAS s Will Benefit The Economy

In addition to being safe and efficient, the UAS s are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the UAS s 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 UAS s is an evolving technology that allows companies greater operational flexibili ty without the high operational cost of a

traditional manned aircraft. By operating the UAS s, 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. Im proved financial performance of

such companies, through commercial use of the UAS s, provides a stable workforce that increases consumer spending; improves l ocal, state, and federal tax revenues

.10

4. General Public Privacy Concerns
Similar to the manned aerial acquisition flight operations that h ave been conducted for decades,
Miracle Films, Inc. proposed operation of the UAS s will not implicate any privacy issues. Specifically, the UAS s will be operated only in compliance with operating documents (i.e., Maintenance Log, and Instruction Manual s ) 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. Miracl e Films, Inc. submits the following representations of enhancements to current aerial motion picture capture techniques:

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

 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 r emote control pilot, and spotter ;

 Miracle Films, Inc. UASs have GPS flight modes and a re d esigned f or a utomatic r eturn

t o h ome p oint i n t he e vent o f l oss o f t he c ontrol l ink, 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 eq ual 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 Film s, Inc. only operat es 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 diminishe d. Third, the small size and ext reme maneuverability of Miracle Films, Inc. UASs allow our re mote 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.11

A Summary the FAA May Publish in the Federal Register: In summary, Miracle Films, Inc. seeks an exemption from the following:

R egulations: 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.

A ccordingly; 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