John Beavers

7LineMedia LLC

547 Newport Drive

Greensburg, PA 15601

724-875-4532

john@7linemedia.com

10/21/2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam,

7LineMedia LLC seeks exemption from the following sections of 14 C.F.R.:

14 C.F.R. 21

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

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) & (b) 14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

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

Reform Act) and 14 C.F.R. Part 11, 7LineMedia LLC (herein referred to as “applicant”),

operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial

videography and photography for the motion picture, television, and commercial

videography industry for closed set filming, hereby applies for an exemption from the

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its

sUASs, so 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.

As described more fully below, the requested exemption would permit the

operation of small, unmanned sUAS under controlled conditions in the NAS that is 1)

limited 2) predetermined 3) controlled as to access. Approval of this exemption would

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibilities to “...establish requirements for the safe operation of

such aircraft systems in the national airspace system.” Section 333(c) of the Reform 

Act.

Page 1
This exemption application is expressly submitted to fulfill Congress’ goal in

passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Lastly, if the Secretary determines that such vehicles “may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. § 333 (c) (emphasis 

added). The Federal Aviation Act expressly grants the FAA the authority to issue

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the

term is defined under §40101 of the Act, that includes sUASs, from the requirement that

all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701 

(f) See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1).

The applicant’s sUASs are rotorcraft, weighing 55 lbs. or fewer, including payload.

They operate, under normal conditions at a speed of no more than 40 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. 

They will operate only in line of sight and will operate only within a predetermined and 

closed off property area under the permission of the property representative. Such 

operations will insure that the sUAS will “not create a hazard to users of the national 

airspace system or the public” as per the Reform Act Section 333 (b). Given the small 

size of the sUASs involved, the restricted sterile environment within which they will 

operate, and the fact that they will be flown by an FAA licensed aircraft pilot, the 

applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the size of the UASs and the restricted 

areas in which the relevant sUASs will operate, approval of the application presents no 

national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent level 

of safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs for movie and commercial videography 

operations, the grant of the requested exemptions is in the public interest. Accordingly, 

the applicant respectfully requests that the FAA grant the requested exemption without 

delay.

Page 2
EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft

that have the characteristics and that operate with the limitations listed herein. These

limitations provide for at least an equivalent or even higher level of safety to operations

under the current regulatory structure because the proposed operations are conducted 

on closed off property under the permission of the property owner or property

representative. Proposed limitations and conditions to which applicant agrees to be 

bound when conducting commercial operations under an FAA issued exemption:

• The PIC will hold a current ASEL (airplane, single engine, land) certificate, and

either an FAA-issued airman medical certificate, or a current U.S. driver’s

license.

Operation of the applicant’s sUAS will be limited to the applicant’s sole

and primary pilot who meets these criteria who’s certification’s are listed

below:

• The sUAS will weigh no more than 55 lbs.

• Flights operations will be outside of five (5) nautical miles from any airport

reference point (ARP). If asked to operate within five (5) miles of an airport, the

applicant will contact the airport's manager and control tower with all flight plans,

as well as the FAA through a normal filing of a Form 7711-1 (or its equivalent)

with the appropriate FSDO. Only upon approval of flight plans from all entities

will we agree to, and conduct, any operation within five (5) miles of an airport.

• Flights will be operated within line of sight (un-aided) of a pilot and/or observer.

• Maximum total flight time for each operational flight will be 20 minutes. Flights

will be terminated at 20% battery power reserve should that occur prior to the 20

minute limit, and no further flights shall be commenced on the same batteries

unless they hold enough energy for a minimum of 5 minutes of flight time, or the

minimum recommended by the craft manufacturer.

• All operations shall be conducted in accordance with an ATO-issued COA

• Flights will be operated at an altitude of no more than 400 feet AGL or, not more

than 200 feet above an elevated platform from which filming is planned. If a

structure being filmed or photographed has a height which exceeds 400 feet AGL,

the UAS will not exceed 100 feet in height above the highest point on that

structure.

• Minimum crew for each operation will consist of the sUAS Pilot, and the Visual

Observer.

Page 3
• sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 30

hours of flight time with the specific sUAS equipment the applicant operates.

The experience of the PIC will be certified by the applicant through background

checks and, if necessary, testing.

• Applicant will maintain flight logs of all PICs it employs, and provide full

transparency to the FAA regarding the logs and records of these PICs, as per 14

CFR § 61.51(b),

• Flights will be operated at a lateral distance of at least 100 feet from any inhabited

structures, buildings, vehicles, vessels, or people not associated with the operation

or who have not signed a waiver in advance of the operation.

• A briefing will be conducted in regard to the planned sUAS operations prior to each

day’s production activities. It will be mandatory that all personnel involved with

the operational duties of the flight within the boundaries of the safety perimeter be

present for this briefing.

• The operator will file an FAA Form 7711-1, or its equivalent, as modified in light

of the requested exemption, with the appropriate local Flight Standards District

Office.

• The operator will obtain the consent of all persons involved in the filming and

ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and this radius may be reduced to 30 feet based upon an equivalent

level of safety determination. With the advanced permission of the relevant

FSDO, operations at closer range can be approved.

• PIC and Visual Observer will have been trained in the operation of the specific

sUAS equipment used by the applicant, and received up-to-date information on

the particular sUAS to be operated.

• The PIC designated for any operation will have at least a Class 2 medical

certificate.

• Visual Observer and PIC will at all times be able to communicate by voice, radio,

and/or text.

• Written and/or oral permission from the relevant property holders or property

representatives will be obtained.

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

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

governmental agencies.

Page 4
• If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS

will have the capability to return to a pre-determined location within the

controlled property, and land autonomously.

• The sUAS will have the capability to abort a flight in case of unpredicted obstacles,

weather, or emergencies.

• sUAS operations will not be conducted at night, as defined in 14 CFR § 1.1

• The sUAS will give way to any and all manned aviation operations and activities, at

all times

• The sUAS will not be operated from any moving vehicle or device

• Any incidents shall be reported to the FAA’s UAS Integration office within 24

hours.

• During operations for closed-set motion picture and television filming and

production, the PIC will have a motion picture and television operations manual

(MPTOM), as seen in this applications docket folder.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR §91.203

(a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular sUAS. In all cases, an 

analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is 55 lbs. or less fully loaded, carries neither a

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area. Unlike other civil aircraft, operations under 

this exemption will be tightly controlled and monitored by both the operator and under 

the requirements and in compliance with local public safety requirements, to provide 

security for the area of operation as is now done with conventional filming. The FAA will 

have advance notice of all operations. These safety enhancements, which already apply 

to civil aircraft operated in connection with motion picture and television production, 

provide a greater degree of safety to the public and property owners than conventional 

Page 5
operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than

6 inches high, the words "limited", "restricted", "light-sport", "experimental", or

"provisional", as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed 

as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAS, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with 

§45.29 (f), and the equivalent level of safety will be provided by having the sUAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer, and others working with the 

sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued the 

following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 

10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command.

The PIC will hold a current, FAA issued, ASEL (aircraft, single engine, land) certificate. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have no less than 40 hours of flight time with the specific sUAS equipment the 

applicant operates. The experience of the PIC will be certified by The applicant through 

background checks and, if necessary, testing.

The applicant will maintain flight logs of all qualified PICs it employees as per 14

CFR § 61.51(b), and provide full transparency to the FAA regarding the logs and records

of these PICs. The PIC designated for any operation will hold an FAA issued pilots

license, and have at least a Class 2 medical certificate, or U.S issued driver’s license. 

The risks associated with the operation of the sUAS are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the sUAS by a PIC meeting the standards of the applicant (listed

above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

Page 6
14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there will be no airworthiness certificate issued for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. The applicant proposes that an equivalent level of safety will be provided

by the use of the following safety checklists prior to each flight in order to determine if

the sUAS is in condition for safe flight:

Aircraft: All adjustment points will be checked for tightness; all motors and

props will be inspected; all wiring will be double-checked; all systems will

be powered up and checked for errors as per the flight systems manuals.

Battery: Confirmation will be made that batteries are fully charged and

installed/connected properly.

Calibration: Pre-flight motor/gyro/compass calibration followed by

confirmation of no errors with the flight and navigation systems.

Transmitter: Confirm radio transmitter has sufficient charge, and is both

working properly and receiving telemetry from the sUAS; confirm all

switches are in pre-flight mode, and that a successful link has been

established between the aircraft transmitter and onboard receiver.

Confirm sufficient satellites are present for navigation system in the event of

failsafe trigger

Home point coordinates are confirmed recorded by navigation system prior to

take-off

Surroundings/Flight Area: Conduct one last visual inspection of the take-off

surroundings and area of airspace sUAS will be operating in. Confirm all

people in the surrounding areas are associated with the operation being

conducted.

Take-off Announcement: Before motors are started the PIC will announce to

a designated Representative (person of authority) of the film crew that sUAS

is ready to take-off. Only after the Representative has notified all persons

within the surrounding areas, and confirmed to PIC that they have clearance

to lift-off, will the motors be started and the sUAS will conduct its

operation.

A mandatory test flight will be conducted after any disassembly/reassembly; after

replacement of any motors or flight electronics; after any pre-flight or in flight equipment

Page 7
errors that occur not resulting from environmental conditions. This will be done before

commercial operation is commenced.

All maintenance, overhaul, replacement, and inspections will be carried out as per

the manufacturers specifications by a knowledgeable and capable person with the

experience necessary to ensure safe operation of the sUAS, and documented in the

aircraft’s records.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane or

Rotorcraft Flight Manual, approved manual material, markings, and placards, or

any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the aircraft component flight

manuals at the ground control point where the PIC flying the sUAS will have immediate

access to it. The FAA has issued the following exemptions to this regulation: Exemption

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and

10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight

to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be

provided for the aircraft, an exemption will be needed.

In order to ensure consistent and safe operation, the PIC will perform pre-flight

inspection, maintenance, and test flights as described above with regards to 14 C.F.R. §

91.7 (a), as well as assess mission specific requirements (flight path, flight time,

obstructions, landing and take-off hazards, aircraft performance, weather, etc) before

commencing operation.

14 C.F.R. § 91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a

manned free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls. sUASs and remotely piloted aircraft, by their design do not

have fully functional dual controls. Flight control is accomplished through the use of a

Page 8
control box that communicates with the aircraft via radio communications. The FAA has

approved exemptions for flight training without fully functional dual controls for a

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.

5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilot

nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section

91.119 (d) allows helicopters to be operated at less than the minimums prescribed,

provided the person operating the helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a

helicopter and the exemption requests authority to operate at altitudes up to 400 feet

AGL, or not more than 200 feet above an elevated platform from which filming is

planned, an exemption may be needed to allow such operations. As set forth herein, the 

sUAS will never operate at higher than 400 feet AGL with the exception that in

circumstances where the sUAS is used to survey or photograph a structure whose 

height exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above 

the highest point on the structure. It will however be operated in a restricted area with

security perimeter, where buildings and people will not be exposed to operations without

their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of

the sUAS as well as the location where it is operated. No flight will be taken without the

permission of the property owner or local officials. Because of the advance notice to the

property owner and participants in the filming activity, all affected individuals will be

aware of the planned flight operations. Compared to flight operations with aircraft or

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of

flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 400 AGL in the 

movie industry. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure airport

or an appropriate altimeter setting available before departure.” As the sUAS may not

have a barometric altimeter, but instead a GPS altitude read out, an exemption may be

needed. An equivalent level of safety will be achieved by the operator, pursuant to the

safety check list and live flight data monitoring, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.

Page 9
14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane

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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the sUAS provides no more than 20 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights

would not be possible due to the reserve requirement being equal to the maximum flight

time. Given the limitations on the sUAS’s proposed flight area and the location of its

proposed operations within a predetermined area, a longer time frame for flight in

daylight or twilight VFR conditions is reasonable.

The applicant believes that an exemption from 14 C.F.R. § 91.151 (a) falls within

the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small

UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of

reserve fuel, does not engender the type of risks that Section 91.151 (a) was intended 

to alleviate given the size and speed of the small UAS. Additionally, the limitations 

created by this requirement for sUAS flights would essentially make null any utility for 

which the exemption will be granted.

The applicant believes that an equivalent level of safety can be achieved by limiting

flights to 20 minutes or 20% of battery power— whichever happens first. This restriction

would be more than adequate to return the sUAS to its planned landing zone from

anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

Page 10
passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and is operated without an

onboard pilot. As such, there is no ability or place to carry certification and registration

documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the

ground control point where the pilot flying the sUAS will have immediate access to 

them, to the extent they are applicable to the sUAS. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. Maintenance and inspections

will be done in accordance with the sUAS Manufacturer's Manual, and will be performed

by employees of the applicant following the guidelines and practices provided to us 

bythe sUAS Manufacturer. An equivalent level of safety will be achieved because these

small UASs are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land

immediately and will be operating from no higher than 400 feet AGL. The PIC will

ensure that the sUAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance performed. Moreover, the PIC is the

person most familiar with the aircraft and best suited to maintain the aircraft in an

airworthy condition to provide the equivalent level of safety.

Additional Views

Regarding Privacy:

All flights will occur over private or controlled access property with the property

representative or owner’s prior consent and knowledge. Filming will be of people who

have also consented to being filmed or otherwise have agreed to be in the area where

filming will take place. All flights will occur in accordance with any state or local laws

regarding privacy.

Additionally, our company seeks to conform to privacy regulations what we believe

are necessary, and imminent, if the UAS industry is to be accepted by the general 

public, and therefore the motion picture and TV industries.

Page 11
Overall Safety and Benefits of Granting Exemption:

1. Helping to shed a positive light on the commercial use of UAS and to set an example in

 safety and professionalism within the industry and hobby as a whole, by the following 

 standards. 

• Encouraging others to spend the necessary time required to be an experienced pilot.

• Being an outward advocate for FAA compliance, stressing the importance of safety and

 following FAA protocol. Line of sight only flights, below 400 feet in altitude, in non-restricted

 airspace.

• Pre and Post-Flight checklists to ensure that batteries, components, and the integrity of the

 aircraft are in order.

• Utilizing a Pilot’s Assistant to ensure that equipment has not been damaged in transport,

 assist with maintenance, verify that the pilot’s pre and post-flight checklists have been

 performed properly, and to assist with safety education before, during, and after the flight(s).

• Respecting and maintaining public privacy.

• Never flying over people or crowds.

• Never flying under the influence of alcohol or other substances.

• Never flying near or around power lines.

• Never flying in high winds or bad weather.

• Providing professional education to the public.

2. Use of UAS verses full scale helicopters provide a safer environment for filming.

3. Provide economic growth for the public by allowing the public to hire 7LineMedia LLC, and

 allowing 7LineMedia LLC to grow and take on employees.

Page 12
Current UAS Systems Operated by 7LineMedia LLC:

Mid-Atlantic Multirotor X8

The X8 is a high-end, co-axial, UAS airframe designed specifically to withstand the rigors of

feature film and television production. It is an extremely stable, smooth-flying, heavy-lifting

platform, built to produce stunning imagery of the highest quality. The design’s flexibility allows

for thousands of combinations of motors and electronics to suit a wide array of applications,

and is compatible with all flight control systems. The airframe’s rigidity comes from it’s 100%

6K carbon fiber plating and durable hardware.

Aircraft Weight (without payload): 18 lb 13 oz

Dimensions: 41.5” (motor to motor) 21.5” (tall)

Max Payload: 35 pounds

Component Material: 6K Carbon Fiber Plate, 3K Carbon Fiber Tube

Propeller: Xoar PJP-T-LU Carbon Fiber 18x6”

Motor: KDE 5215 XF 435

Flight Controller: DJI A2 + iOSD MKII

Video Downlink: Connex by Ammimon + DJI Lightbridge 2

Batteries: QuadroPower 6s 10000mah (in parallel)

Page 13
DJI S900

Supporting a total takeoff weight of 18 pounds, the Spreading Wings S900 Hexacopterfrom DJI

is optimized for installing a gimbal such as the Zenmuse Z15 enabling capture of aerial videos

and photos. It features carbon fiber frame arms to cut down on weight, which fold down for

storage and transport.

Aircraft Weight (without payload): 7.3 lb

Diagonal Wheelbase: 35.4 in

Max Payload: 10.8 lb

Component Material: Carbon Fiber

Propeller: Folding Plastic, 15x5.2”

Motor: DJI 4110

Flight Controller: DJI A2 + GPS/Compass Pro

Video Downlink: DJI Lightbridge

Batteries: QuadroPower 6s 10000mah

Page 14
DJI Inspire 1

The DJI Inspire 1 is a quad copter that utilizes a revolutionary new flight controller that allows for

extremely accurate flight both in and outdoors, and boasts a 4K camera, and flight times

exceeding 15 minutes. This unit also has a built in 720p video transmission system, complete

with full telemetry.

Aircraft Weight: 6.5 lb

Dimensions: 17.2 x 17.8 x 11.9 in

Propeller: Plastic, Model 1345

Motor: DJI 3510

Flight Controller: DJI Professional

Video Downlink: Built-in 720p

Batteries: DJI Model TB48

Page 15
DJI Phantom 3

The DJI Inspire 1 is a quad copter that utilizes a revolutionary new flight controller that allows for

extremely accurate flight both in and outdoors, and boasts a 4K camera, and flight times

exceeding 20 minutes. This unit also has a built in 720p video transmission system, complete

with full telemetry.

Aircraft Weight: 2.8 lb

Dimensions (diagonal including propellers): 23.2 in

Propeller: Plastic, Model 9450

Motor: DJI Phantom Motor

Flight Controller: DJI Professional

Video Downlink: Built-in 720p

Batteries: 4S 4480MAH

Page 16
Pre-Flight Procedure

• Check the reliability of the Multi-Rotor.

• The flight battery and transmitter battery must be fully charged.

• Always turn on the transmitter first and then the Multi-Rotor.

• Watch for visible damage such as loose screws, broken, unbalanced or damaged propellers,

 faulty connectors or solder joints, broken pipes, etc.

• The propeller must be in a good condition and securely mounted. The rotors must spin

 smoothly. Please ensure that there are no objects are in the rotational plane of the propellers

 or within a distance that poses a risk of obstruction. Rotating propeller ends are dangerous to

 touch - never touch a rotating propeller with fingers or other body parts.

• Ensure the appropriate to the audible beeps when auto lipo-detection is enabled. 6 * beep

 means 6s Lipo

• Ensure that the selected channel on the remote control is free and that you're within range of

 the transmitter.

• Ensure the sensors are calibrated (when the motors are off move yaw and gas stick into upper

 left corner until it beeps).

• Different settings can result in fundamentally different flight characteristics and occupation of

 the Channel functions. Make sure that you are familiar with the setting and its features.

• After starting the motors, check that all motors are running and rotate evenly. Please fly

 carefully at a low altitude until you know that everything is working fine.

• Perform a pre-flight check (see checklist below).

• Start manually - switch off altitude control and GPS.

Pre-Flight Checklist

• Weather conditions are suitable.

• Frame and all screws are tight.

• Propeller not damaged and tightly fixed.

• Battery fully charged and securely mounted.

• Transmitter battery charged and the antennas are free.

• Channel of the transmitter is not busy. If 35/40/70MHz or other MHz-RC-controls are in

 operation simultaneously, the used channels must be checked with the other pilots (not

 necessary for 2.4 GHz systems).

• Check RC(TX/RX) operation range (on the ground!) from time to time (and before 1st flight).

• Ensure there is nothing in the danger zone of the propeller.

• Ensure enough space for launch and flight.

• Ensure the GPS module (if any) has GPS fix. If CH or PH is active it will beep every second.

 Check that when you switch to GPS mode, there will be an audible beep.

• For manual start ensure GPS and altitude controls are turned off.

• Ensure sensors are calibrated and that the right setting is loaded.

• Ensure the trim of the remote control is in neutral position.

Page 17
In-Flight Procedure

• Do not take risks! Your own safety and that of your environment depend on the good behavior

 of the pilot. Always maintain a safe distance from people, animals and objects. Improper

 operation can cause serious injury and property damage! Never fly towards viewers and avoid

 flying over spectators.

• Keep in mind that viewers could get close to the Multi-Rotor, without being aware of potential

 dangers.

• Always turn off the Multi-Rotor first and disconnect the flight battery before turning off the

 transmitter.

• Only fly in line of sight. In the case of manual control, you must be able to see the position and

 altitude. Never fly over 400 feet.

• Never rely 100% on functions such as GPS, compass, or altitude control. You must always be

 able to take manual control of the Multi-Rotor.

• Reduce the throttle or switch off the motors in case of a crash or failure.

• Do not fly in restricted air space, such as in the vicinity of airports, etc.

• Pay attention to under-voltage warning -flying on an empty battery can cause damage to the

 Lipos and crash.

• If a defect or malfunction has occurred, it must be corrected before the next start.

• When using GPS, take note that the position of the Multi-Rotor can change suddenly.

•

Post-Flight Procedure

• Disconnect the battery and check all over for damage. Make sure that there is no damage to

 the propellers.

• See the Handling and safety precautions of Lipo batteries.

• If the Multi-Rotor is involved in a crash or hard landing the sensors and electronics might be

 damaged. Before the next start everything must be checked.

Page 18
Similar granted petitions are as follows: 2/18/2015 Picture Factory, Inc., 2/13/2015 Capital

Aerial Video, LLC., 2/10/2015 Blue-Chip UAS, 2/3/2015 Helinet Aviation Services, LLC.,

2/3/2015 Alan D. Purwin, 1/29/2015 Slugwear, bda Likeona Tree, 1/29/2015 Team 5, 1/29/2015

Shotover, 1/23/2015 AeroCine, 1/23/2015 Burnz Eye View, 1/6/2015 Douglas Trudeau,

12/10/2014 Clayco, 10/10/2014 Flying Cam, 9/25/2014 Astraeus Aerial, 9/25/2014 Aerial MOB,

9/25/2014 Pictorvision, 9/25/2014 HeliVideo Productions, 9/25/2014 Snaproll Media, 9/25/2014

RC Pro Productions Consulting, dba Vortex Aerial.

In Summary, 7LineMedia LLC. with its pilot and observer seek exemption from the

following regulations: 14 C.F.R. Part 21, 14 C.F.R. Part 45.23 (b), 14 C.F.R. Part 91.7 (a), 14

C.F.R Part 91.9 (b)(2), 14 C.F.R. Part 91.103, 14 C.F. R Part 91.109 (a), 14 C.F.R. Part 91.119,

14 C.F.R. Part 91.121, 14 C.F.R., Part 91.151 (a), 14 C.F.R. Part 91.203 (a) & (b) , 14 C.F.R.

Part 91.405 (a), 407 (a)(1), 409 (a)(1) & (2), 417 (a) & (b), to commercially operate their

sUAVs, weighing under 55 pounds, in a safe manure and to provide the public awareness

and safety.

If granted the exemption from the FAA 7LineMedia LLC will continue to abide by the

FAA regulations and policies set in place. If granted the exemption 7LineMedia LLC will submit a

Certificate of Waiver or Authorization (COA) before any commercial jobs are performed .

Commercial operations would include but are not limited to, aerial footage for the film industry,

TV productions, real estate, surveying for development, agriculture inspection, aerial mapping.

Sincerely,

10/21/2015

John Beavers

Owner, 7LineMedia LLC

Page 19
Appendix of Attachments:

1. 7LineMedia proof/certificate of insurance via Walton Suder & Penn National Insurance.

2. DJI A2 User Manual

3. DJI S900 Manual

4. DJI Inspire 1 User Manual

5. DJI Phantom 3 Manual

Page 20