Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 1 UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



## Cinematic Aerospace, Inc.

FOR AN EXEMPTION S EEKING RELIEF FROM
THE REQUIREMENTS OF THE FAA REFORM ACT AND

PART 11 OF THE FEDER AL AVIATION REGULATI ONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.11 3 (a) & (b); 61.133 (a); 91.7(a); 91.119 ; 91.121; 91.151(a); 91.405 (a) ; 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted	on February	16 th

, 2016

Cinema tic	Aerospace,	Inc.

399	Conklin	Street

Suite	304 Farmingdale,	NY 1 1735 info@cinematicaerospace.comCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 2 

### Table	of	Contents

Glossary	of	Abbreviations

................................ ................................ ................................ ..... 3

Introduction	And	Interests	Of	The	Petitioner

................................ ................................ 4

Executive	Summary

................................ ................................ ................................ ................ 4 Expeditious	Summary	Grant	Approval	Request

................................ ........................... 4 Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:

................................ ............. 5 Commercial	(Mission,	Operation)	Purpose

................................ ................................ ......................... 6 Regulations	from	which	the	Exemption	Relief	is	requested:

................................ ....................... 7

The	name	and	address	of	the	Petitioner:

................................ ................................ .............................. 7 Background

................................ ................................ ................................ ............................... 7 Member	Biographies

................................ ................................ ................................ .............. 8
Expertise	&	Experience

................................ ................................ ................................ ............................. 10 Commitment	to	Safety

................................ ................................ ................................ ............................... 10

The	Exemption	Request

................................ ................................ ................................ ..... 11 Operator	Requirements

................................ ................................ ................................ ..... 13 Specific	Uses	Public	Benefits

................................ ................................ ............................ 14 Equivalent	Level	of	Safety

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

- in

- Command

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

................................ ................................ .............. 16 14	C.F.R.	§91.119:	Minimum safe	altitudes

................................ ................................ ....................... 16 14	C.F.R.	§91.121:	Altimeter	Settings

................................ ................................ ................................ .. 16 14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Condition s

.............................. 17 14	C.F.R.	§91.405	(a);	91.407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance Inspections

................................ ................................ ................................ ................................ ...................... 17

Federal	Register	Publicat ion

................................ ................................ ............................ 18

Privacy	and	National	Security

................................ ................................ .......................... 19

Summary

................................ ................................ ................................ ................................ . 19

APPENDIX	A

- TECHNICAL	MANUALS	AN D	SPECIFICATIONS

................................ .. 21

APPENDIX	B

- COMMERCIAL	(MISSION/OPERATION)	PURPOSE

- FAA	PREVIOUS

APPROVED	EXEMPTION	NUMBERS

................................ ................................ ................ 22

APPENDIX	C

– UAS	EQUIPMENT

- FAA	PREVIOUS	APPROVED	EXEMPTION

NUMBERS

................................ ................................ ................................ ................................ . 23

APPENDIX	D

- EXEMPTION	14	C.F.R

- FAA	PREVIOUS	APPROVED	EXEMPTION

NUMBERS

................................ ................................ ................................ ................................ . 24

APPENDIX	E

– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATION

MANUAL

- VERSION	v1.0

................................ ................................ ................................ ..... 25Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 3 

## Glossary	o f	Abbreviations

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	o f	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS Global	Posit ioning	System

LOL Loss	of	Link

MPTOM Motion	Picture	and	Television	Operation	Manual

NAS National	Airspace	System

NOTAM Notice	t o	Airman

PIC Pilot

- i n

- Command

Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333

SO Safety	Observ er
SOP Standard	Operating	Procedures

sUAS Small	Unmanned	Aircraft	System

sUAV Small	Unmanned	Aircraft	Vehicle

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

UAV Unmanned	Aircraft	Vehicle

VFR Visual	Flight	Rules

VLOS Visual	Line	o f	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Take

- Off	and	LandingCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 4 

## Introduction	And	Interests	Of	The	Petitioner

Dear	Sir	or	Madam:

Pursuant	 to	 Section	 333	 of	 the	 FAA	 Modernization	 and	 Reform	 Act	 of	 2012	 (the “Reform	 Act”)	 and	 14	 C .F.R.	 Part	 11, Cinematic	 Aerospace,	 Inc.	 (“Cinematic Aerospace”), Operator	of	Small	Unmanned	Airc raft	Systems	(“sUAS ’ s”) equipped	 to

offer	 on

- demand	 commercial	 UAS	 operations	 for	 a	 host	 of	 industries	 and applications and to perform the	 purposes	 listed	 belo w
, hereby	 applies	 for	 an exemption	 from	 the	 listed	 Federal	 Aviation	 Regulations	 (“FARs”)	 to	 allow

c ommercial	operation	of	its	sUAV s /UAS ,	so	long	as	such	operations	are	conducted within	 and	 under	 the	 conditions	 outlined	 herein	 or	 as	 may	 be	 established	 by	 th e FAA	 in	 an	 exemption	 granted	 under	 either	 Section	 333	 or Section	 49	 U.S.C. §44701(f).

As	 described	 more	 fully	 below,	 the	 requested	 exemption	 would	 permit	 the operation	 of	 a UAS	 under	 controlled	 conditions	 in	 airspace	 that	 is	 1)	 limited;	 2) predetermined; and	3)	would	provide	safety	enhancements	in	the	fields	in	which	it will	 operate,	 which	 now	 depend	 upon	 conventional	 aircraft	 or	 humans	 climbin g high	 on da ngerous	 structures,	 walking	 in	 insect	 laden	 swamps,	 and	 working adjacent	 to	 treacherous	infrastructur e. Approval	 of	 this	 exemption	 would	 thereby enhance	 safety	 and	 fulfill	 the	 Sec retary	 of	 Transportation’s	 (the FAA Administrator’s)	responsibilities	to	“... establish	requirements	for	the	safe	operation of	 such	 aircraft	 systems in	 the	 national	 airspace	 system ” ( S ection	 333(c)	 of	 the Reform	Act). 1



## Executive Summary

Expeditious	Summary	Grant	Approval	Request

The	 petitioner	 requests	 the	 agency	 issue	 a	 summary	 grant	 process	 for	 this application .	 Petitioner	 has	 provided through	 the	 information	 contained	 in	 this

document ,	specific	exemption	numbers and	examples whereby	the	FAA	has	already granted	a	previous	exemption	similar	or	identical	to	each	and	every	request,	herein.

1 Cinematic	Aerospace	relies	upon	the	following	exemptions	where	specific reference	to	an	exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080, 11109	through	11112,	11114,	11213,	11062	and	as	recent	as	11857.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 5 Petitioner	 has	identified three or	more previous	 approved	 exemptions for	 each	 of

the	Petit ioners	FAA	submission	requests:

• Commercial	(mission/operation)	purposes (Appendix	B) ;

• Type	of	sUAV s	(UAS) (Appendix	C) ;

• Title	14	Exemptions ( Appendix	D )



### Description	of Type,	Make	and	Models	of	sUAV/UAS	Requested:

The	petitioner	is	seeking	an	exempt ion	 t o	commercially	operate sUAV s	makes	and

mode l s	as	follows:

1 .	3D	Robotics

- Solo 8 .	DJI

- Spreading	Wings S1000

2 .	DJI

- Inspire	1 9.	DJI

- Spreading	Wings	S1000 +

3.	DJI

- Matrice	100 10.	Freefly

- Alta

4 .	DJI

- Phantom	2 11.	Hubsan

- X4	Microdrone

5

. DJI

- Phantom	3 12.	Intuitive	Aerigon	IAH3

6.	DJI

- Spreading	Wings	S800 13.	Parrot

- Bebop 2

7.	DJI

- Spreading	Wings	S900 14 .	Yuneec

- Typhoon	Q500

E ach	 separately	 weighs	 55	 lbs.	 or	 less,	 with	 imaging	 payload	 and	 applicable equipment.

Equipment	o peration	manuals	for	each	sUAV	are	included	for	your	reference

.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 6 

### Commercial	(Mission,	Operation)	Purpose

This	exemption	request

, once	granted	would	allow	the	petitioner	to	operate	a	small unmanned	aerial	vehicle	(sUAV),	unmanned	aircraft system	(UAS )	to	conduct	bridge

i nspections,	flare	stack	inspection,	utility

- power	generation	system	inspections	and patrolling,	 aerial	 inspection,	 photography	 and	 videography	 of	 residential	 and

commercial real	estate,	weddings ,	aerial	inspection,	photography	and	 vide ography of	 utility	 infrastructure	 including	 but	 not	 limited	 to	 electrical	 power	 lines,	 wind turbines	 and	 cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking, cinematography,	 and	 videography,	 precision	 agriculture	 with	 on	 board	 sensors,

wildlife	and forestry	monitoring and	mosquito	and	insect	control, aeri al	surveying and	3D	mapping ,	construction	site inspection	and	monitoring,	pub lic	entity	support operations,	 a erial	 imaging	 for	 safety,	 monitoring	 and	 comparing	 work	 efforts	 and completion	 percentage s,	 and	 security	 of	 controlled	 environment	 of	 various	 sites, aerial	 video	and	live	 video	 feed	 to	assist	with	 search	and	 rescue	 operations	under the	authority	and	support	of	local	authority	officials,	aerial	video	and	photography for	 public	and	 private	 use	i ncluding	 television,	 public	events,	and	 cinematography live	 feed	 and	 live	 newsgathering,	 training	 to	 persons	 individually	 or	 belonging	 to both	private	and	public	organizations	to	increase	awareness	and	improve	safety	for

current	 and	 futur e	 UAS	 operations	 w ithin	 the	 NAS, special events:	 including	 high schools, colleges,	 professional	 sports,	 open	 air	 events	 and	 fairs ,	 research,	 risk management	 and	 assessment,	 motion	 picture	 production 2 ,	 surface	 mining,	 closed

set	 filming 3

, disaster	 and	 catastrophe	 events,	 and vehicle	 accident	 i nvestigati ons (with	proper	law	enforcement	permission)

.

Vehicle	 accident	 investigations	 provides	 the	 opportunity	 to	 evaluate hundreds	 of vehicle	 accidents	 every	 year	 to	 determine	 the	 cause	 of	 an	 accident.	 These inspections	 commonly	 invo lve	 examination	 of	 the	 affected	 vehicles	 as	 well	 as documenting	 conditions	 at	 the	 site	 where	 the	 accident	 occurred.	 Site	 inspections may	 require	 close	 examination	 to	 identify	 details	 such	 as	 skid	 marks,	 grade variations,	roadway	defects,	ect.	B road ,	overal l	views	across	a	large	area	are	helpful for	 such	 an	 investigation	 but	 often	 cannot	 be	 feasibly	 obtained	 using	 traditional fixed	wing	or	rotorcraft	aircrafts.

Aerial	images	provided	by	UAS	would	aid	in	the	analysis	of	vehicle	pathways,	traffic

behavior	 at intersections,	 and	 visualizing	 the	 general	 area	 of	 the	 accident. Knowledge	gained	from	vehicle	accident	investigations	is	used	by	the	transportation industry	 to	improve	public	safety.	When	necessary,	local	law	enforcement	shall	be

used	 to	 establish	 a	 secur e	 zone	 around	 a	 traffic	 intersection	 to	 allow	 aircraft operations	per	the	guidelines.

2 Motion	Picture and	Television	Flight	Operation Manual is	herein	attached	as Appendix	E

. 3 Motion	Picture	and	Television	Flig ht	Operation Manual	for	closed

- set	filming is

herein attached	as	Appendix	E

.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 7 

### Regulations	from	which	the	E xemption Relief	is	requested :
14	C.F.R.	§	61.113	(a)	&	(b) 14	C.F.R.	§	61.133(a) 14	C.F.R.	§	91.7(a)

14	C.F. R. §	91.119 14	C.F.R.	§	91.121

14 C.F.R.	§	91.151	(a) 14	C.F.R.	§	91.405	(a) 14	C.F.R.	§ 91. 407	(a)	(1) 14	C.F.R.	§ 91. 409	(a)	(2) 14	C.F.R.	§ 91. 417	(a)	&	(b )

See	Appendix D for	a	sample	list	of	previously	approved	exemptions	from	14	C.F.R.



### The	name	and	address	of	the	Petitioner :

Cinemat ic	Aerospace,	Inc.

Attn: Christian T. Tucci

399	Conklin	Street

Suite	304 Farmingdale,	NY	11735

Please	direct	any	question	or	comment	regarding	this	petition	to Christian	Tucci	at

the	above	address	and tu cci@cinematicaerospace.com or (516)	308

- 1037

.



### Background

The Petitioner

, Cinematic	 Aerospace

, is under Christian	 Tucci	 and	 David

Windmiller’s direction

. Christian	 and	 David are h ighly	 accomplished,	 capable, experienced

, and trusted	professional s

.

Cinem atic	Aerospace is	a	newly	formed entity	that will	be	a	premiere	aerial	imaging and	 video	 company based	 on	 the	 east	 coast .	 The	 company	 utilizes	 the	 latest	 and most	advanced	unmanned	aircraft	systems	(UAS)	to	bring	safety	and	cost	efficiency

to	customers	acr oss	many	different	applications. Cinematic	Aerospace has	networks in	 residential	 and	 commercial	 real	 estate,	 aerial	 site	 investigation,	 recreational action	 sports,	maritime	industries,	 personal	injury	 litigation/investigation, motion picture	and	television production, and	more.	The	exemption	request,	once	granted,

will	 allow Cinematic	 Aerospace to	 operate	 small	 unmanned	 aerial	 vehicles	 and unmanned	aircraft	systems	to	conduct	photography	and	videography	of	commercial and	 residential	 real	 estate,	 aerial	 site inspection,	 film	 making,	 cinematography, construction	 site	 inspection,	 accident	 scene	 inspection,	 search	 and	 rescue operations	 with	 the	 support	 of	 local	 authorities	 and	 officials,	 special	 events,	 risk management	and	assessment,	and other	forms	of	aerial	i maging.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 8 Christian	Tucci	and	David	Windmiller found ed the	company .	Each	company	member specializes	in	critical	aspects	of	the	business	with	a	keen	awareness	and	recognition of	the	primary	common	goal	of	“safety	first”.	As	provided	in	their	biographies,	each

member holds	many	years	of	experience	under	their	belts.

Although Cinematic	 Aerospace is	 a	 newly	 formed	 startup,	 its President

, Christian

Tucci ,	has	a	long	history	of	flight	operations,	particularly	in	the motion	picture	and television	 industry. This	 typ e	 of work has	 reinforced	 “safety	 first”,	 systems reliability,	 and	 systems	 maintenance	 as	 the	 paramount	 benchmark	 for	 safe	 and successful	 flights.	 This	 continued	 emphasis	 on	 safety	 will	 be	 the	 primary	 concern and	 building	 block	 wherever Cinematic	 Aerospace operates	 its	 aircraft. David

Windmiller has	 been	 a businessman	 and	 pilot for over 34	 years	 specializing	 in

aerobatics

. The	experience	of	running	multiple	successful	businesses	as	well	as	the intense	regime	of	training	that	goes	with	being	an	aerobatic	pilo t	has	also	resulted in	David’s	 “safety	 first”	 attitude	in	 everything	 he	 does,	 especially	 aviation.	David’s safety	 first	 attitude	 also	 stands	 to	 be	 the	 primary	 principal	 in	 which	 Cinematic Aerospace	operates	on	any	job.



### Member	Biographies

Christian	Tucci

Christian brings	a	strong	background	in aerial	cinematography	and	electronics and his	level	of	knowledge	in closed

- set	aerial	cinematography	operations is	considered

advanced. Christian is currently	working	on	his	private	pilot	license	and	will	be one of t he	company’s	designated	pilot s

. He is also currently pursuing	a	bachelor’s	degree in	Business	Management	with	a	focus	in Entrepreneurship	and a	minor	in	Film	and Television	Production	from	Fairfield	University.

Since	 age	 13

, Christian	 has	 work ed extensive ly	 in	 the	 aerial	 cinematography industry. From	the	beginning,	Christian	learned	the	business	from	his	now	long

- time friend	 and	 mentor,	 Al	 Cerullo,	 of	 Hover

- Views	 Unlimited,	 Inc.	 the	 east	 coast’s	 top aerial	 film	 pilot	 and	 aerial	 cinematography	 company. He	 c urrently	 owns	 and operates	Christian	Tucci	Enterprises,	Inc.	a	premier	aviation	and	filmmaking	related consulting	 firm	 based	 on	 Long	 Island,	 New	 York.	 	 Christian	 provides	 a	 variety	 of services	 in	 the	 aerial	 cinematography	 industry	 to	 a	 multitude	 of	 clients including aerial	 coordination	 and	 safety,	 cinematography,	 photography,	 digital	 imaging technician	services,	and	post

- production	editing.

Part	 of	 Christian’s	 work	 with	manned	 helicopters	involves	 working	 as	 part	 of	 the flight	crew	while	on	film	production s.	He	posse sse s	a	knowledge	of	helicopters	and safety	 operations	 that	 ensure	 the	 cast	 and	 crew	 of	 a	 production	 remain	 safe	 and effective	 while	 working	 around	 aircraft	 at	 an	 airport,	 heliport,	 or	 in	 the	 field.

Christian	 strives	 for	 a “ 120% ” safe	 operation, something	 that	 is	 necessary	 while working	around	 full	size	 turbine	helicopters	and	airplanes.	While	UAS	prove	 to	beCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 9 safer in	many	areas because	 of	 their	much	 smaller	 size,	 Christian’s	experiences	in manned	 aircraft	 safety	 operations	 will	 no	 doubt	 be	 an ass et	 to	 Cinematic Aerospace’s attitude	of	“safety	first”.

Christian	 also	 has	 a	 large	 background	 in	 working	 with	 clients	 to	 assist	 in	 their various	 FAA	 paperwork	 needs	 in	 regards	 to	 aerial	 cinematography and	 motion picture/television operations,	including in the	Washington	D.C.	SFRA.	He	has	a	solid understanding	 of	 the	 various	 filing	 requirements	 and	 methods	 and	 has	 years	 of filing	experience	 for	Motion	 Picture and	Television	 Flight	Operation Manuals,	 FAA Plan	 of	 Activities,	 FAA	 COAs,	 and	 FAA/TSA	 FRZ	 Waivers for	 the	 Washington	 D.C. area.	This	existing	experience	proves to	be valuable	 to	 the	kind	of	regulations	 that Cinematic	 Aerospace	 will	 be	 held	 to	 for	 it’s	 primary	 mission	 of	 closed

- set filmmaking.

Christian’s	 piloting	 experience	 includes	 20+	 hours	 in an	 AS 355F1	 TwinStar helicopter	plus 15+	hours	in	single	engine	and	multi

- engine	 fixed

- wing	aircraft,	all

within	the busy	New	York	area	airspace	and 50+	hours	in	flying	various	UAS.	He	is currently	 training	 for	 his	 private	 pilot	 license	 at	 Republic	 Airport	in	 Fa rmingdale,

NY.

Christian has	 al so	 worked	 extensively	 within	 airport	 operations,	 where	 he	 is licensed	 to	operate vehicles	within	 the	secured	safety	perimeter	of	 the	airfield.	He understands	 the	complexities	of	 the	commercial airport environment,	and	his	 ti me
in the	 aviation world working	 at	 the	 airport has	 given	 him	 a	 full	 apprec iation	 for safety	in	aviation.

David	Windmiller David’s	background	in	aviation	and	business	prove s to	be	an	excellent combination for	the	UAS	industry.	The	fast

- paced	growth	of	thi s	industry	is	the	perfect	match	for

David’s	own	fast

- paced

, “full	speed	ahead” attitude.

David’s	 amazing	 resume	 of	 aviation	 experience	 began	 when	 he	 soloed	 on	 his	 16 th birthday.	He	obtained	his	flight	instructor	rating	at	age	18	and	since	then	has logged over	17,900	 flight	hours,	including	4000+	turbine	hours and 200 +	hours with	UAS. These	hours	have	been	logged	over	a	large	number	of	experiences	that	most	in	the aviation	industry	only	dream	of doing .	David	has	secured	certificates	and	ratings	in

numerous fields	including	his	airline	 transport	pilot	AMEL,	commercial	pilot ASEL

and	 SESEA ,	 rotorcraft

- helicopter	 and	 glider.	 He	 is	 a	 certified	 flight	 instructor	 in airplanes,	single	and	multi

- engine	as	well	as	rotorcraft/helicopters,	has	a	type	rating

for	CE	500 all	variants,	a	single	pilot	Cessna	Citation	FAA	waiver,	an	FAA	aerobatic competency	waiver	for	Level	1, and a	curre nt	class	II	medical	certificate.

David’s	 flying	 experience	 continues	 through	 various	 unique	 opportunities	 such	 as working	as	a	test	pilot	f or	Teledyne	Continental	Motors	and	Extra	Aircraft,	where	he also	is	a	factory	sponsored	pilot.	He	was	a	member	of	the	USA	Unlimited	Aerobatic

Team	 from	1999

- 2001	and	placed	4 th in	the	World	Aerobatic	Championship .	DavidCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 10 currently	performs	as	an	air	show	pi lot	and	is	the	owner	and	chief	pilot	of	Vxperts Aviation,	an	Upset	Prevention	and	Recovery	Training	Flight	School.	He	has	worked closely	with	the	FAA	on	a	number	of	FAA	FAAST	Team	Seminars	where	he	has	run spin	 seminars	 and	 demonstrations.	David	 also	 volun teers	 as	 a	Wounded	Warriors and	Special	Olympics	transporter.

David’s	work	in	 the	aerial	cinematography	industry	includes	credits	such	as	Royal Pains,	The	Path,	The	Mysteries	of	Laura,	Blind	Spot,	and	Gold. He	is	a	member	of	the

Screen	Actors	Guild.

Davi d	Windmiller	is	committed	to	safety	and	tirelessly	strives	for	excellence	in	all	he

does	as	well	as a super	efficient	and	safe	operations.



### Expertise	&	Experience

Christian	Tucci and David	Windmiller have professional experience	and a re trusted

sUAV pilot s wo	are extremely	qualified and are	considered up

- and

- coming subject

mat t er	 expert s in	 the New	 York/East	 Coast area for	UAS of	 all	 types,	models

, and

makes.



### Commitment	to	Safety

As	part	of	its	commitment	 to	safety	and	innovation,	Cinematic	Aerospace	is	as king for	 this	 exemption	 in	 part,	 to	 reduce	 the	 risk	 of	 injury	 to	 its	 employees	 and contractors	 who	 participate	 in	 the	 proposed	 activities	 the	 petitioner	 requests, including	 but	 not	 limited	 to	 damage	 to	 agriculture,	 natural	 habitat,	 buildings	 and

other	stru ctures	within	the	United	States.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 11 

## The	Exemption	Request

Cinematic	 Aerospace proposes the	 use	 of the	 sUAV s	 will	 be	 for capture	 of	 high resolution	 imagery	 and	 video	 of	 residential	 or	 commercial	 applications	 and

purposes
, to	 a	 level	 of	 quality	 that	 allows	 th e	 Petitioner	 to	 use	 the	 imagery	 to identify,	 record, and memorialize	 events	 and	 objects	 according	 to	 the	 purposes

noted.

The	 imagery	 and	 video	 will	 be	 used	 to	 identify	 the	 condition	 of	 landscapes, agriculture,	events,	disasters

, and	infrastructure to	con duct	bridge i nspections,	flare stack	inspection,	utility

- power	generation	system	inspections	and	patrolling,	aerial inspection,	photography	and	videography	of	residential	and	commercial real	estate, weddings ,	aerial	inspection,	 photography	and	 videography of	 utility	infrastructure including	 but	 not	 limited	 to	 electrical	 power	 lines,	 wind	 turbines	 and	 cell	 towers, pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	 videography, precision	 agriculture	 with	 on	 board	 sensors,	 wildlife	 and	 forestr y	 monitoring and mosquito	 and	 insect	 control, aerial	 surveying and	 3D	 mapping ,	 construction	 site inspection	 and	 monitoring,	 public	 entity	 support	 operations, a erial	 imaging	 for safety,	 monitoring	 and	 comparing	 work	 efforts	 and	 completion	 percentages,	 and

s ecurity	of	controlled	environment	of	various	sites,	aerial	video	and	live	video	feed to	assist	with	search	and	rescue	operations	under	the	authority	and	support	of	local authority	officials,	aerial	video	and	photography	for	public	and	private	use	including television,	 public	 events,	 and	 cinematography	 live	 feed	 and	 live	 newsgathering, training	 to	 persons	 individually	 or	 belonging	 to	 both	 private	 and	 public organizations	to	increase	awareness	and	improve	safety	for	current	and	futur e	UAS operations	 within	 th e	 NAS, special	 events:	 including	 high	 schools

, colleges, professional	 sports,	 open	 air	 events	 and	 fairs research,	 risk	 management	 and assessment,	motion	picture	pro duction,	surface	mining,	closed

- set	 filming, disaster and	 catastrophe	 events,	 and	 vehicle	 ac cident	 investigations (with	 proper	 law enforcement	permission)

.

The	UAS	will	be	operated	by	a Cinematic	Aerospace	and/or	contracting	operator(s)

on	occasion to	capture	high

- resolution	imagery/video	of	large	structures	(wide	and tall)	such	as	warehouses, high	rise buildings,	bridges,	and	construction	sites,	as	well

as	 “bird ’ s	eye”	 views	 of	 fire	and	explosion sites. Given	 the	 small	 size	 of	 the sUAV s involved,	no	more	than	5 5 lbs., majority	of	the speed	of	operation will be	between	5

- 50 mph and	 the	 restricte d	 environment	 within	 which	 they	 will	 operate,	 the

Petitioner 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 i mmediately

.

This	exemption	application	is	submitted	 to	 fulfill	Congress’	express	goal	in	passing Sections	 333(a)	 through	 (c)	 of	 the	 Reform	 Act.	 This	 law	 directs	 the	 Secretary	 of Transportation to	 consider	 whether	 certain	 unmanned	 aircraft	 systems	 mayCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 12 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	UA 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	s ight	of	the	Operator.

Reform	 Act	 §	 333	 (a).	 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	airs pace	system. ” Id.	§333(c)	(emphasis	added). 4

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: Th e	 Administrator	 may	 grant	 an exemption	 from	 a	 requirement	 of	 a	 regulation prescribed	 under	 subsection	 (a)	 or (b)	of	 this	section	or	any	of	sections 44702

- 44716	of	 this	 title	if	 the	Administrator finds	 the	 exemption	is	in	 the public	interest. 49	U.S.C.	 §447 01(f).	 See	 also	 49	USC §44711(a);	49	USC	§44704;	14	CFR	§91.203(a)(1)

.

Cinematic	Aerospace	i n	filing	this	application	is	requesting	that	the	FAA	combine	the grant	of the	Section	333	exemption	with	a	standard	Certificate	of	Operation	(COA)

that	will	allow commercial	operations	of Cinematic	Aerospace’s sUAV s without	the necessity	of	filing	for	a	COA	for	each flight,	unless	such	flight	is	to	be	conducted	in	an area	 not	 approved	 in	 the	 exemption. Compliance with	 the	 conditions	 agreed	 to herein	 and	 that	 may	 be imposed	 by	 the	 FAA,	 as	 set forth	 in	 prior	 Section	 333 exemptions,	provide	the	separation	needed	from	other	aircraft.

In	addition,	given	that	all	operations	will	be	conducted	below	400	AGL	 feet	and	no

closer than	5	nautical	miles	of	 the	geographic	center	o f	an	airport	as	denoted	on	a

current	 FAA published aeronautical	 chart,	 unless	 a	 letter	 of	 agreement	 with	 that airport’s	 management	 is obtained, Cinematic	 Aerospace requests	 that	 operations over	congested	or	densely	populated	areas	be allowed. The	new sUAV s do have	GPS

geo

- fencing,	 it	 will	 operate	 at	 a	 very	 low	 altitude,	 within confined	 areas,	 at	 low speed	 and	 weighs	 no	more	 than 55 lbs. Such	 operations	 will	 only	 be under

- taken with	 the	approval	of	 the	land	or	home	owner ,	as	set	 forth	herein,	and	will comply with	 the	 requirements	 that	 operations	 be	 no	 closer	 than	 500	 feet	 to	 the	 adjacent

4 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administr ator	to	not	only process	applications	for	exemptions	under	section	333,	but	for	the	Administrator	to craft	conditions	for	the	safe	operation	of	the	UAS,	if	it	should	be	determined	that	the conditions	set	forth	herein	do	not	fulfill	the	statutory	requiremen ts	for	approval.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 13 building	unless the	land	owner	has	provided	permission,	and	the	Operator	has	made a	safety	assessment	of the	risk	from	such	operations.



### Operator	Requirements

Advanced	sUAV s have a	navigation	and	control	system	and	auto

- pilot	that	allow s it

to execute	 very	 accurate	 pr e

- programed	 flights.	 Flights	 can	 be p re

- programmed with	 GPS	 waypoint s to	 establish	 perimeters	 beyond	 which	 the	 aircraft	 will	 not operate.	 Flights	 under	 auto

- pil ot	 are not	 directed	 by	 positive	 manual	 input,	 but through	 pre

- programmed	 flight	 parameters	 that	are executed	 by	 the	auto

- pilot.	 In the	 case	 of	 unplanned	 events,	 the	 Operator	 inputs	 pre

- programmed evasive maneuvers	from	the	control	unit,	and	the	autopilot	e xecutes	those maneuvers.	Pre

programmed Operator	 interventions	 include : initiation	 of	 holding	 at	 present position;	 suspension	 of	 mission;	 fly	 back	 to	 launch	 point;	 abort	 mission	 and	 land immediately; and	 emergency	 power	 cut	 off	 and	 land	 (flight	 termination system). Additional	 automated	 safety	 functions	 and	 safety	 enh ancin g	 features	 of	 the

advanced	sUAV s may include	the	following:

1) Auto

- pilot	 detection	 of	 lost	 GPS	 or	 of	 insufficient	 satellites	 initiates	 an

immediate landing, 2) Low	power	on	the	aircraft triggers	escalating	alarms	at	GCS	at	35%	and	10%

levels. Low	power	be low 10 %	triggers	an	immediate	landing, 3) If	the	auto

- pilot	detects	a	lost

- link	to	the	ground	controller,	the	UAS	will	hold position at	its	current	location	for	5	seconds	and	if	the	si gnal	is	not	restored,

execute	a	return to	home	and	land, 4) Redundant	“kill	switches”	that	enable	completely	shutting	the	aircraft	down in	flight	in the	event	of	a	loss	of	control	or	un

- commanded	devi ation	from	the flight	path, 5) The	aircraft,	weighs 55 lbs. or	less ,	fully	loaded, 6) The	motors	are	driven	by	pulse	width	modula ted	signals,	not	analog	signals, 7)	The aircraft	will	operate	for	the	p urposes	at	no	more	than 100 mph

, nor above

a	maximum	of	400	fe et AGL.

Nonetheless,	 Cinematic	 Aerospace	 u nderstands	 the	 importance	 of	 maintaining	 a knowledge	 of	 conventional	 aircraft operating procedures	 and	 airspace	 use regulations	as	well	as	ATC	operations.	As	such,	Cinematic	Aerospace	 requests	 that an	exemption	be	made	with	similar	conditions	in	terms	of	o perator	requirements	to recent	exemptions	approve d	by	the	FAA,	such	as	found	in numbered	paragraphs 6, 13,	and	14	of	Exemption	14519.

As	 to	 national	 security	 review	 of	 pilots,	 each	 of Cinematic	 Aerospace ’s pilots/operators	 will	 obtain	 interna lly	 provided certified	 training ( Ground	 and Practical)	 from Cinematic	 Aerospace t o	 o perate the sUAV .	 This	 review andCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 14 certification could reasonably vet	 the	Operators	against	any	known	 terrorist	or	no fly	listings	that	are	relevant and	publically	available.



### Specific	Us es	Public	Benefits

Cinematic	Aerospace proposes	use	 of	its sUAV providing equivalent	 or	augmented

levels	of safety	for	each	of	the	uses	proposed	herein:

The	pre sent	systems	of	photography,	videography,	mapping	and in specting of roofs, agriculture	 land, buildings and	 large structures

, site	 surveys, wild	 life	monitoring,

and mosquito	 and	 insect	 control are	 now	 conducted	 by	 either a	 person wading through	swamps, climbing	on	the	roofs and	structures	that	are	steep,	tall,	slippery,

weakened

, or	otherwise	haz ardous	or	by	the	use	of conventional	aircraft.

The	 current	 procedures	 can	 result	 in	 significant	 injuries	 to	 the	 people	 who must climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude	greater

in	 size than	 the	 sUAV .	 Either	 method,	 m anual	 inspection	 or	 large	 conventional aircraft,	 results	 in increased	 risk	 of	 injury	 due	 to	 personnel	 falling	 off	 roofs	 or ladders,	 carrying	 heavy	 ladders

, dealing	 with	 confined	 and	 dangerous	 spaces,	 or

i ncreased	 risk	 from	 low	 altitude flyovers	 with helico pters	 or	 fixed	 wing	 aircraft inspecting	 buildings	 after	 damage	 from	 storms	 or	 other disasters,	 such	 as earthquakes	 or	 fires.	Such	 flights	are,	 of	 course,	 significantly	more expensive	 t han

those	undertaken	with	a	sUAV

.

The	present	system	exposes	those	not only	in the	immediate	area	of	inspection,	but those	who	are	along	 the	path	of	 flight	associated	with	 the arrival	and	departure	of the	 conventional	 aircraft	 at	 the	inspection	 site or	 filming	 site because	 the	 aircraft

must be	flown	to	and	from the	site.	By contrast,	the	sUAV is	carried	to	the	site	and

transits	no	other property.	Conventional	aircraft	carry	flammable	fuels	that	are	not carried	by	the	UAS	and	emit pollutants	associated	with	inter n al	combustion	engines.

The	sUAV s	proposed	herein	are battery	pow ered	and	have	no	emissions.

For	these	main	reasons,	Cinematic	Aerospace	finds	this	petition	for	exemption	to	be in	the	public	benefit	now	and	in	the	future.



### Equivalent	Level	of	Safety

14	C.F.R.	§	61.11 3(a)	&	(b): Private	Pilot	Privileges	and Limitations; Pilot

- in

Command

Section	61.113(a)	&	(b)	limit	private	pilots	to	non

- commercial	operations.	Unlike	a

conventional aircraft	 that	 carries	 a	 pilot,	 passengers,	 and	 cargo,	 the Cinematic Aerospace sUAV is	remotely	controlled	with no	passengers	or	property	of others	onCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 15 board.	Section	61.133(a)	requires	an	individual	with	a commerc ial	pilot’s	license	to be	pilot

- in

- command	of	an	aircraft	for	compensation	or	hire.

Cinematic	Aerospace respectfully	proposes	that	Operator	requirements	should	take

into	account	 the characteristics	of	 the	particular	UAS. Cinematic	Aerospace ’s sUAV has	 a	 high	 degree	 of	 pre

- programmed control	 and	 various	 built

- in	 technical capabilities	 that	 strictly	 limit	 the	 potential	 for	 operation outside	 of	 the	 operating

conditions	 set	 forth	 in	 the	 e xemption	 application. The sUAV has	 navigation	 and control	system s comprised	of	a	Ground	Control	Station (GCS)	and	auto

- pilot	system that	can	be	pre

- programme d	to	set	operational	boundaries

. In	the	case	of	unplanned events,	 the	 Operator	 may	 input	 pre

- progra mmed evasive	 maneuvers	 from	 the control	unit,	and	the	onboard	autopilot	executes	those	maneuvers. Pre

- programmed Operator	interventions	include	initiation	of	holding	at	present	position; suspension of	 mission;	 fly	 back	 to	 launch	 point;	 abort	 mission	 and	 la nd	 immediately;	 and emergency	power	cut	off	and	land	(Flight	Termination	System).

Additional	automated	 safety	 functions	and	 safety	enhancing	 featur es	 of	 the sUAV s

may include	the following:

1.1.	Auto

- pilot	 detection	 of	lost	GPS	 or	 of	insuf ficient	 satelli tes	initiates	an

immediate landing. 1.2.	Low	power	on	the	aircraft	triggers	escalati ng	alarms	at	GCS	at	35%	and

10% levels.	Low	power below 10%	triggers	an	immediate	landing.

1.3.	If	the	auto

- pilot	detects	a	lost

- link	to	the	groun d	controller,	the	UAS	will

hold position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not restored, execute	a	return	to	home	and	land. 1.4.	 Redundant	 “kill	 switches”	 that	 enable	 completely	 shutt ing	 the	 aircraft down	 in	 flight in	 the	 event	 of	 a	 loss	 of	 control	 or	 un

- co mmanded deviation	from	the	flight	path.

1.5.	T he	aircraft,	weighs 5 5 lbs. or	less ,	fully	loaded. 1.6.	 The	 motors	 are	 driven	 by	 pulse	 width	 modulated	 signals,	 not	 analog signals.

1.7.	The aircraft	will	operate	for	the	p urposes at	no	more	than 100 mph

, nor above a maximum altitude of	400 feet AGL.

Given	 these	 safety	 features, Cinematic	 Aerospace	 proposes	 that	 Operators	 of	 the

sUAV s should not	b e	required	to	hold	a	commercial pilot	certification.

Given	 these	 conditions	 and	 restrictions,	 an	 equ ivalent	 leve l	 of	 safety	 will	 be provided	by	allowing operation	of	the sUAV without	a	commercial pilot’s	certificate,

under	the	conditions	set	forth	herein.

The	risks	associated	with	the	operation	of Cinematic	Aerospace sUAS (giv en	its	size, speed,	operational capabil ities,	and	lack	of	combustible	fuel)	are	so	diminished	from

the	level	of	risk	associated with commercial pilot	operations	contemplated	by	Part

61	with conventional	aircraft	(fixed	wing	or	rotorcraft),	that	allowing	operations	of

the	 UAS	 as	 set	 forth above meets	 or	 exceeds	 the	 present	 level	 of	 safety	 providedCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 16 under	 14	 C.F.R.	 §	 61.113(a)	 &	 (b) and	 does	 not	 rise	 to	 the	 level	 of	 requiring	 a commercial	pilot	to	operate	the	aircraft	under §	61.133(a).

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

This	 regul ation	 requires	 that	 no	 person	may	 operate	 a	 civil	 air craft	 unless	it	is	in airworthy condition.	 Should	 the	 exemption	 be	 granted	 allowing	 commercial operation	of	the	UAS	without an	airworthiness	certificate,	no	standard	will	exist	for

airworthiness	of	the	U A.	Given	the	size	of the	aircraft	and	the	requirements	that	the Operator	has	agreed	to	as	it	relates	to	airworthiness, as	contained	in	the	manual,	an equivalent	level	of	safety	will	be	achieved	by	insuring compliance	with	the	manuals prior	to	each	flight. The	FAA	has	granted	exemptions	to	conduct similar	operations in	Exemptions	11062	through	11067,	11080	and	11110.

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

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

91.119 (d)	allow s	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	exempti on	 requests	authority to	 operate	at	altitudes	 up	 to 4 00 AGL,	an	exemption	may	be	needed	to	allow	such	operations.

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

the	UAS as	well	as	the	location	where	it	is	operated.	N o	flight	will	be	taken	without the	permission	of	the property	owner,	facility	owner,	and/or	local	officials.	Because

of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals will	be	aware	of	the	planned	flight operations	as	se t	forth	in	the	m anuals.	Compared to	flight	operations	with	aircraft	or	rotorcraft weighing	far	more	than	the	maximum 55	lbs.	and	 the	lack	of	 flammable	 fuel,	any	risk	associated with	 these	operations	is far	 less	 than	 those	 presently	 presented	 by	 conventiona l	 aircraft operating	 at	 or below	 500	 AGL	 in	 the	 aerial	 photography	 industry.	 In	 addition,	 the	 low

- altitude operations	of	 the	sUAS	will	ensur e	separation	between	 these	s UAS	operations	and

the operations	of	conventional	aircraft	 that	must	comply	with	Section 91.119.	The FAA	 has	 granted exemptions	 to	 conduct	 similar	 operations	 in	 Exemptions	 11062 through	11067,	11080	and 11110.

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

This	 regulation	 requires	 each	 person	 operating	 an	 aircraft	 t o	 maintain	 cruising altitude	by re ference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure airport	or	an	appropriate altimeter	setting	available	before	departure.”	As sUAV s ,	inCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 17 manual	 or	 emergency mode,	 will	 not	 have	 a	 barometric	 altimeter	 display,	 but

instead	a	GPS	altitude display,	an exemption	will	be	needed. The	Operator,	pursuant

to	t he	procedures	set	forth	in	the	m anuals	as	indicated	before	flight,	will	achieve	an equivalent	 level	 of	 safety .	 The	 FAA	 has granted	 exemptions	 to	 conduct	 similar operations	in	Exemptions	1106 2	through	11067,	11080 and	11110.

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	 c onditions) 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	 p owering	 the	 sUAS	 provides	 appr oximately	 30 minutes or	 less of powered flight. As	 such

, sUAS	 are	 not	 able	 to	 meet	 the 30

- minute reserve requirement	in	 14	 CFR	 §91.151. Given	 the	limitations	 on	 the	UA S’ proposed	 flight

area	 and the	 location	 of	 its	 proposed	 op erations	 within	 a	 predetermined	 area, in addition	 to	 the	 various	safety	and	GPS

- based	 “return

- to

- home”	 features	present	in the	UAS,	an	equivalent	level	of	safety	is	provided.

Petitioner believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	sc ope 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	w ho	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.

Petitioner believes	 that	 an	 equivalent	 level of	 saf ety	 can	 be	 achieved	 by	 limiting flights	 to 25%	 of remaining battery	 power.	 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, 10673,	10808	and	Exemptions	11062,	through 11067,

11080	and	11110.

14	C.F.R.	§91.405	(a);	91.407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance
Inspections

These	 regulations	 require	 that	 an	 aircraft Operator	 or owner	 “shall	 have	 that

aircraft inspected	as	pr escribed	in	S ubpart	E	of	this	part	and	shall	between	required inspections,	except as	provided	in	paragraph	(c)	of	this	section,	have	discrepanciesCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 18 repaired	 as	 prescribed	 in	 P art 43	 of	 this	 chapter. ..,”	 and	 others	 shall	 inspect	 or

maintain	the	aircraft	in	c ompliance	with	P art	43.

Given	 that	 these	 sections	and	Part	 43	apply	 only	 to	aircraft	with	an	airworthiness certificate,	 these	 sections	 will	 not	 apply	 to	 the Petitioner .	 Maintenance	 will	 be

accomp lished	 by the	Operator	 or	manufacturer	 pursuant	 to	 the	 flight	manual	 and operating	 handbook	 as referenced	 in	 the	 m anuals	 att ached

. This e xhibits	 a n 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	defined	are as	 for	limited periods	of	time. As	provided	in the	Aircraft	Flight	Operations	Manual

, the	Operator will	 ensure	 that	 the	 UAS	 is	 in	 working	 order prior	 to	 initiating	 flight,	 perform required	maintenance,	and	ke ep	a	log	of	any	maintenance performed.	Moreover,	the Operator	 and	 manufacturer	 are	 most	 familiar	 with	 the	 aircraft	 and best	 suited	 to maintain	 the	 aircraft	 in	 an	 airworthy	 condition	 to	 provide	 the	 equivalent	 level	 of safety.	The	FAA	has	granted	exemptions for	similar	operations	in	Exemptions	11062 through 11067,	11080	and	11110.

*********



## Federal	Register	Publication

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is provided	for	publication	in

the Federal	Register,	should	it	be	determined	that	publ ication	is	needed:

Petitioner seeks	an	exemption	from	the	following	rules:

14	 C.F.R.	 §§	 61.113(a)	 &	 (b); 61.133(a); 91.7(a);	 91.119;	 91.121;	 91.151(a); 91.405(a); 91.407(a)(1);	91.409(a)(2)	and	91.417	(a)	&	(b)	to	operat e	commercially

a	 small	 unmanned ve hicle	 (55	lbs.	 or	less) for	 the	 following	 purposes: to	 conduct bridge	 i nspections,	 flare	 stack	 inspection,	 utility

- power	 generation	 system inspections	 and	 patrolling,	 aerial	 inspection	 and	 photography	 of	 residential	 and commercial	utility	infrastructure	in cluding	but	not	limited	to	electrical	power	lines, wind	 turbines	 and	 cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking, cinematography,	 and	 videography,	 precision	 agriculture	 with	 on	 board	 sensors, wildlife	and	 forestry	monitoring and	mosquito	an d	insect	control ,	aerial	surveying and	3D	mapping ,	construction	site	inspection	and	monitoring,	public	entity	support operations,	 aerial	 video	 and	 live	 video	 feed	 to	 assist	 with	 search	 and	 rescue operations	under	the	authority	and	support	of	local	authorit y	officials,	aerial	video and	photography	for	public	and	private	use	including	television,	public	events,	and cinematography	live	feed	and	live	newsgathering,	training	to	persons	individually	or belonging	 to	 both	 private	 and	 public	 organizations	 to	 increas e	 awareness	 and improve	 safety	 for	 current	 and	 futur e	 UAS	 operations	 within	 the	 NAS, special events:	 including	 high	 schools, colleges,	 professional	 sports,	 open	 air	 events	 and

fairs ,	 research,	 risk	 management	 and	 assessment,	 motion	 picture	 pro duction,Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 19 surf ace	 mining,	 closed

- set	 filming, disaster	 and	 catastrophe	 events,	 and	 vehicle accident	investigations.



## Privacy	and	National	Security

All	flights	will	occur	over property	on	which the	property	owner’s prior	consent	and knowledge has	been	obtained .	Inspecti on	will	be	of	inanimate	objects	in	areas

where	the	owners will	have	consented	to	the	inspections	or	otherwise	have	agreed

to	allow	the	UAS	and	the Operator	to	be	in	the	area	where operations will	take	place.

The	size	of	the	UAS,	its	speed	and	restricted area	of	operation	do	not	raise	national security	issues.



## Summary

Approval	of	exemptions	allowi n g	commercial	operations	of	sUAV s	 for petitioner	to operate	 an	 unmanned	 aircraft system	 (UAS)	 to	 conduct	 bridge	 i nspections,	 flare stack	inspection,	utility

- po wer	generation	system	inspections	and	patrolling,	aerial inspection	 and	 photography	 of	 residential	 and	 commercial	 utility	 infrastructure including	 but	 not	 limited	 to	 electrical	 power	 lines,	 wind	 turbines	 and	 cell	 towers, pipeline	 inspection	 and	 patrolling, filmmaking,	 cinematography,	 and	 videography, precision	 agriculture	 with	 on	 board	 sensors,	 wildlife	 and	 forestry	 monitoring and mosquito	 and	 insect	 control ,	 aerial	 surveying and	 3D	 mapping ,	 construction	 site inspection	 and	 monitoring,	 public	 entity	 support operations,	 aerial	 video	 and	 live video	 feed	 to	 assist	 with	 search	 and	 rescue	 operations	 under	 the	 authority	 and support	 of	 local	 authority	 officials,	 aerial	 video	 and	 photography	 for	 public	 and private	 use	 including	 television,	 public	 events,	 and	 cinemat ography	 live	 feed	 and live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and public	 organizations	 to	 increase	 awareness	 and	 improve	 safety	 for	 current	 and

futur e	 UAS	 operations	 within	 the	 NAS

, special events:	 including	 high	 s chools, colleges,	professional	sports,	open	air	events	and	 fairs ,	 research,	 risk	management and	 assessment,	 motion	 picture	 pro duction,	 surface	 mining,	 closed

- set	 filming, disaster	 and	 catastrophe	 events

, and	 vehicle	 accident	 investigations	 (with	 proper

law enforcement	permission), will	enhance safety	by	reducing	risk.

Conventional	 operations,	 using	 jet	 or	 piston	 powered	 aircraft,	 ladders	 or placing people in	swamps, on	roofs	or	tall,	hazardous	or	weakened	structures,	exposes	them to	 higher	 risks tha n those created	 by	 use	 of sUAVs .	 Conventional	 aircraft	 that operate	at	extremely	low altitudes	just	feet	from	the	subject	being	inspected	and	in extreme	 proximity	 to	 people	 and structures	 present	 the	 risks	 associated	 with vehicles	that	weigh	in	excess	of	6,000	lb s.,	carrying large	amounts	of	jet	A	or	other fuel	(140	gallons	 for	jet	helicopters).	Such	aircraft	must	 fly	to	and from	the	proje ct location.	In	contrast,	a	sUAV weighing	fewer	than 55 lbs.	and	powered	by batteriesCinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 20 eliminates	virtually	all	of	that	risk	giv en	the	reduced	mass	and	lack	of	combustible

fuel carried	 on	 board.	 The	 sUAV is	 carried	 to	 the	 target	 area	 and	 not	 flown.	 Th e sUAV will	carry	no passengers	or	crew	and,	 therefore,	will	not	expose	 them	 to	 the

risks	associated	with	manned aircraft	flights.

T he	operation	of	sm all	UASs,	weighing	less	than 5 5 lbs.,	conducted	under	the	strict conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow

spe eds,	close	to	the ground,	and	in	areas	that	are	under	the	control	of	the	customer

for	 the operations and,	 as	 a result,	 are	 far	 safer	 than	 conventional	 operations

conducted	 with	 turbine or	 piston helicopters	 operating	 in close	 proximity	 to	 the ground	and	pe ople	or	 the	use	of	individuals	 to	climb	 the	structures	 to conduct	 the operations

.

Satisfaction	of	the	criteria	provided	in	Section	333	o f	the	Reform	Act	of	2012

– size, weight,	speed,	operating	capabilities,	proximity	to	a irports	and	populated	areas	and operation within	 visual	 line	 of	 sight	 and	 nation al	 security

– provide	 more	 than adequate	 justification	 for	 the grant	 of	 the	 requested	 exemptions	 allowing commercial	operation	of Petitioner ’s	UAS	 for	 the p urposes	outlined	herein	and	are

consistent	with	exem ptions	already	granted,	including Exemptions 11 171	 through
11174,	11176,	11177, 11062,	11109,	11112,	and	11213 and as	recent	as	11857.

Sincerely,

Christian	T.	Tucci

President

tucci@cinematicaerospa ce.com /	(516)	308

- 1037

Cinematic	Aerospace,	Inc.

399	Conklin	Street

Suite	304 Farmingdale,	NY	11735Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 21 

### APPENDIX	A

- TECHNICAL	MANUALS	AN D	SPECIFICATIONS

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contain s proprietary	 confidentia l	 business	 information	 that is	 not	 released	 to	 the	 public

pursuant	to 14	C.F.R.	§11.35(b).	The	provisions	of	this	document	are	privileged	and confidential.	Unauthorized	reproduction	or	distribution	of	 this	document	or	any	of its	contents	in	any	form	or	und er	any	circumstances	without	prior	written	consent is	prohibited.

Submitted	under	separate	cover.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 22 

### APPENDIX	B

- COMMERCIAL	(MISSION/OPERATION)	PURPOSE

- FAA

PREVIOUS	APPROVED	EXEMPTION	NUMBER S

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDE NTIAL,”	 as	 it contain s proprietary	 confidential	 business	 information	 that is	 not	 released	 to	 the	 public

pursuant	to 14	C.F.R.	§11.35(b).	The	provisions	of	this	document	are	privileged	and confidential.	Unauthorized	reproduction	or	distribution	of	 this	docu ment	or	any	of its	contents	in	any	form	or	under	any	circumstances	without	prior	written	consent is	prohibited.

Submitted	under	separate	cover.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 23 

### APPENDIX	C

– UAS EQUIPMENT

- FAA	PREVIOUS	APPROVED	EXEMPTION

NUMBER S

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contain s proprietary	 confidential	 business	 information	 that is	 not	 released	 to	 the	 public

pursuant	to 14	C.F.R.	§11.35(b).	The	provisions	of	this	document	are	privileged	and

confidential.	Unauthori zed	reproduction	or	distribution	of	 this	document	or	any	of its	contents	in	any	form	or	under	any	circumstances	without	prior	written	consent is	prohibited.

Submitted	under	separate	cover.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 24 

### APPENDIX	D

- EXEMPTION 14	C.F.R

- FAA	PREVIOUS	APPROVED

EXEMPTIO N	NUMBER S

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contain s proprietary	 confidential	 business	 information	 that is	 not	 released	 to	 the	 public

pursuant	to 14	C.F.R.	§11.35(b).	The	provisions	of	this	document	are	privileged	and

co nfidential.	Unauthorized	reproduction	or	distribution	of	 this	document	or	any	of its	contents	in	any	form	or	under	any	circumstances	without	prior	written	consent is	prohibited.

Submitted	under	separate	cover.Cinematic	Aerospace,	Inc. 399	Conklin	Street.,	Suite 304

, Farmingdale,	NY	11735 www.CinematicAerospace.com ( 516 ) 308

- 1037 Page 25 

### APPENDIX	E

– MOTION	PICTUR E AND	TELEVISION	FLIGHT	OPERATION

MANUAL

- VERSION v 1.0

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contain s proprietary	 confidential	 business	 information	 that is	 not	 released	 to	 the	 public

pursuant	to 14	C.F.R.	§11.35(b).	The	pro visions	of	this	document	are	privileged	and confidential.	Unauthorized	reproduction	or	distribution	of	 this	document	or	any	of its	contents	in	any	form	or	under	any	circumstances	without	prior	written	consent is	prohibited.

Submitted	under	separate	cover

.