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

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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 SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 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); 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	16th,	2016

Cinematic	Aerospace,	Inc.

399	Conklin	Street

Suite	304

Farmingdale,	NY 11735

info@cinematicaerospace.com
Cinematic	Aerospace,	Inc. 		399	Conklin	Street.,	Suite	304,	Farmingdale,	NY	11735		

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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	Conditions .............................. 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	Publication............................................................................................ 18

Privacy	and	National	Security .......................................................................................... 19

Summary ................................................................................................................................. 19

APPENDIX	A	- TECHNICAL	MANUALS	AND	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..................................................................................................... 25
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Glossary	of	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	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS    Global	Positioning	System

LOL Loss	of	Link

MPTOM Motion	Picture	and	Television	Operation	Manual

NAS National	Airspace	System

NOTAM Notice	to	Airman

PIC Pilot-in-Command

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

SO Safety	Observer

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	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Take-Off	and	Landing
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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	Aircraft	Systems	(“sUAS’s”)	equipped	 to	

offer	 on-demand	 commercial	 UAS	 operations	 for	 a	 host	 of	 industries	 and	

applications and	 to	 perform	 the	 purposes	 listed	 below, hereby	 applies	 for	 an	

exemption	 from	 the	 listed	 Federal	 Aviation	 Regulations	 (“FARs”)	 to	 allow	

commercial	operation	of	its	sUAVs/UAS,	so	long	as	such	operations	are	conducted	

within	 and	 under	 the	 conditions	 outlined	 herein	 or	 as	 may	 be	 established	 by	 the	

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	 climbing	

high	 on	 dangerous	 structures,	 walking	 in	 insect	 laden	 swamps,	 and	 working	

adjacent	 to	 treacherous	infrastructure. 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).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.
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Petitioner	 has	identified	three or	more previous	 approved	 exemptions for	 each	 of	

the	Petitioners	FAA	submission	requests:

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

• Type	of	sUAVs	(UAS) (Appendix	C);

• Title	14	Exemptions	(Appendix	D)

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

The	petitioner	is	seeking	an	exemption	 to	commercially	operate	sUAVs	makes	and	

models	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

Each	 separately	 weighs	 55	 lbs.	 or	 less,	 with	 imaging	 payload	 and	 applicable	

equipment.

Equipment	operation	manuals	for	each	sUAV	are	included	for	your	reference.
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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	

inspections,	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 forestry	monitoring and	mosquito	and	insect	control, aerial	surveying

and	3D	mapping,	construction	site	inspection	and	monitoring,	public	entity	support	

operations,	 aerial	 imaging	 for	 safety,	 monitoring	 and	 comparing	 work	 efforts	 and	

completion	 percentages,	 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	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	 future	 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	 production2,	 surface	 mining,	 closedset	 filming3, disaster	 and	 catastrophe	 events,	 and vehicle	 accident	 investigations

(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	 involve	 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.	Broad,	overall	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	 secure	 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	Flight	Operation Manual	for	closed-set	filming	is	

herein	attached	as	Appendix	E.
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Regulations	from	which	the	Exemption	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:

Cinematic	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	tucci@cinematicaerospace.com or (516)	308-1037.

Background

The	 Petitioner, Cinematic	 Aerospace, is under	 Christian	 Tucci	 and	 David	

Windmiller’s	 direction.	 Christian	 and	 David are highly	 accomplished,	 capable,	

experienced, and	trusted	professionals.

Cinematic	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	across	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	imaging.
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Christian	Tucci	and	David	Windmiller founded 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	 type	 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	pilot	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 the	company’s	designated	pilots.	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	 worked extensively	 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	 currently	 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	productions.	He	possesses	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	be	
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safer in	many	areas because	 of	 their	much	 smaller	 size,	 Christian’s	experiences	in	

manned	 aircraft	 safety	 operations	 will	 no	 doubt	 be	 an asset	 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	 AS355F1	 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	 Farmingdale,	

NY.

Christian has	 also	 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	 time	

in	the	 aviation world working	 at	 the	 airport	 has	 given	 him	 a	 full	 appreciation	 for	

safety	in	aviation.

David	Windmiller

David’s	background	in	aviation	and	business	proves to	be	an	excellent combination	

for	the	UAS	industry.	The	fast-paced	growth	of	this	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	 16th

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	current	class	II	medical	certificate.

David’s	 flying	 experience	 continues	 through	 various	 unique	 opportunities	 such	 as	

working	as	a	test	pilot	for	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	4th in	the	World	Aerobatic	Championship.	David	
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currently	performs	as	an	air	show	pilot	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	 volunteers	 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.

David	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 are trusted	

sUAV	pilots wo	are	extremely	qualified	and	are	considered	up-and-coming	subject	

matter	 experts 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	asking	

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	structures	within	the	United	States.
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The	Exemption	Request

Cinematic	 Aerospace proposes the	 use	 of	 the	 sUAVs	 will	 be	 for capture	 of	 high	

resolution	 imagery	 and	 video	 of	 residential	 or	 commercial	 applications	 and	

purposes, to	 a	 level	 of	 quality	 that	 allows	 the	 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	conduct	bridge	inspections,	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	 forestry	 monitoring and	

mosquito	 and	 insect	 control, aerial	 surveying and	 3D	 mapping,	 construction	 site	

inspection	 and	 monitoring,	 public	 entity	 support	 operations,	 aerial	 imaging	 for	

safety,	 monitoring	 and	 comparing	 work	 efforts	 and	 completion	 percentages,	 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	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	future	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	production,	surface	mining,	closed-set	 filming,	disaster	

and	 catastrophe	 events,	 and	 vehicle	 accident	 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 sUAVs	

involved,	no	more	than	55 lbs.,	majority	of	the	speed	of	operation	will	be	between	5-

50 mph and	 the	 restricted	 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 immediately.

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	 may
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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’ 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.

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	airspace	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: The	 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.	 §44701(f).	 See	 also	 49	USC	

§44711(a);	49	USC	§44704;	14	CFR	§91.203(a)(1).

Cinematic	Aerospace	in	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	sUAVs 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	of	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 sUAVs 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	Administrator	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	requirements	for	approval.
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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	sUAVs have a	navigation	and	control	system	and	auto-pilot	that	allows it	

to execute	 very	 accurate	 pre-programed	 flights.	 Flights	 can	 be pre-programmed	

with	 GPS	 waypoints to	 establish	 perimeters	 beyond	 which	 the	 aircraft	 will	 not	

operate.	 Flights	 under	 auto-pilot	 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	executes	those maneuvers.	Preprogrammed	 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	 enhancing	 features	 of	 the	

advanced	sUAVs 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	below 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	signal	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	deviation	from	the	

flight	path,	

5)	 The	aircraft,	weighs 55	lbs. or	less,	fully	loaded,	

6)	 The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals,	

7)	The aircraft	will	operate	for	the	purposes	at	no	more	than	100 mph,	nor above	

a	maximum	of	400	feet AGL.

Nonetheless,	 Cinematic	 Aerospace	 understands	 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	operator	requirements	to	

recent	exemptions	approved	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	 internally	 provided	 certified	 training	 (Ground	 and	

Practical)	 from	 Cinematic	 Aerospace to	 operate the	 sUAV.	 This	 review and	
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certification could	reasonably vet	 the	Operators	against	any	known	 terrorist	or	no	

fly	listings	that	are	relevant and	publically	available.

Specific	Uses	Public	Benefits

Cinematic	Aerospace proposes	use	 of	its	 sUAV providing equivalent	 or	augmented	

levels	of safety	for	each	of	the	uses	proposed	herein:

The	present	systems	of	photography,	videography,	mapping	and inspecting	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	hazardous	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,	 manual	 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	

increased	 risk	 from	 low	 altitude	 flyovers	 with helicopters	 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	 than	

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	internal	combustion	engines.	

The	sUAVs	proposed	herein	are battery	powered	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.	§	61.113(a)	&	(b): Private	Pilot	Privileges	and	Limitations; Pilot-inCommand

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	on	
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board.	Section	61.133(a)	requires	an	individual	with	a commercial	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	 exemption	 application. The	 sUAV has	 navigation	 and	

control	systems comprised	of	a	Ground	Control	Station (GCS)	and	auto-pilot	system	

that	can	be	pre-programmed	to	set	operational	boundaries.	In	the	case	of	unplanned	

events,	 the	 Operator	 may	 input	 pre-programmed 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	 land	 immediately;	 and

emergency	power	cut	off	and	land	(Flight	Termination	System).

Additional	automated	 safety	 functions	and	 safety	enhancing	 features	 of	 the	 sUAVs

may	include	the following:

1.1.	Auto-pilot	 detection	 of	lost	GPS	 or	 of	insufficient	 satellites	initiates	an	

immediate landing.

1.2.	Low	power	on	the	aircraft	triggers	escalating	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	ground	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	 shutting	 the	 aircraft	

down	 in	 flight	 in	 the	 event	 of	 a	 loss	 of	 control	 or	 un-commanded	

deviation	from	the	flight	path.

1.5.	The	aircraft,	weighs 55	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	purposes 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	

sUAVs should not	be	required	to	hold	a	commercial	pilot	certification.	

Given	 these	 conditions	 and	 restrictions,	 an	 equivalent	 level	 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 (given	its	size,	

speed,	operational	capabilities,	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	 provided	
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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	 regulation	 requires	 that	 no	 person	may	 operate	 a	 civil	 aircraft	 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	UA.	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)	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	

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.	No	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	set	forth	in	the	manuals.	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	 conventional	 aircraft operating	 at	 or	

below	 500	 AGL	 in	 the	 aerial	 photography	 industry.	 In	 addition,	 the	 low-altitude

operations	of	 the	sUAS	will	ensure	separation	between	 these	sUAS	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	 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	sUAVs,	in	
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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	the	procedures	set	forth	in	the	manuals	as	indicated	before	flight,	will	achieve	an	

equivalent	 level	 of	 safety.	 The	 FAA	 has granted	 exemptions	 to	 conduct	 similar	

operations	in	Exemptions	11062	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	 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	 approximately	 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	UAS’ proposed	 flight	

area	 and the	 location	 of	 its	 proposed	 operations	 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	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.

Petitioner believes	 that	 an	 equivalent	 level of	 safety	 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	prescribed	in	Subpart	E	of	this	part	and	shall	between	required	

inspections,	except as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	
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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	 Petitioner.	 Maintenance	 will	 be	

accomplished	 by the	Operator	 or	manufacturer	 pursuant	 to	 the	 flight	manual	 and	

operating	 handbook	 as referenced	 in	 the	 manuals	 attached. This	 exhibits	 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	defined	areas	 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	keep	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	publication	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	operate	commercially	

a	 small	 unmanned	 vehicle	 (55	lbs.	 or	less)	for	 the	 following	 purposes:	to	 conduct

bridge	 inspections,	 flare	 stack	 inspection,	 utility-power	 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	

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

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surface	 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.	Inspection	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	allowing	commercial	operations	of	sUAVs	 for	petitioner	to	

operate	 an	 unmanned	 aircraft	 system	 (UAS)	 to	 conduct	 bridge	 inspections,	 flare	

stack	inspection,	utility-power	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	 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	

future	 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	 production,	 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 than 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	lbs.,	carrying large	amounts	of	jet	A	or	other	

fuel	(140	gallons	 for	jet	helicopters).	Such	aircraft	must	 fly	to	and from	the	project	

location.	In	contrast,	a	sUAV weighing	fewer	than	55 lbs.	and	powered	by batteries	
Cinematic	Aerospace,	Inc. 		399	Conklin	Street.,	Suite	304,	Farmingdale,	NY	11735		

www.CinematicAerospace.com		(516)	308-1037 Page	20

eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack	of	combustible	

fuel carried	 on	 board.	 The	 sUAV is	 carried	 to	 the	 target	 area	 and	 not	 flown.	 The	

sUAV will	carry	no passengers	or	crew	and,	 therefore,	will	not	expose	 them	 to	 the	

risks	associated	with	manned aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	55 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	

speeds,	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	people	or	 the	use	of	individuals	 to	climb	 the	structures	 to conduct	 the	

operations.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	– size,	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	

operation within	 visual	 line	 of	 sight	 and	 national	 security	 – provide	 more	 than	

adequate	 justification	 for	 the grant	 of	 the	 requested	 exemptions	 allowing	

commercial	operation	of	Petitioner’s	UAS	 for	 the purposes	outlined	herein	and	are	

consistent	with	exemptions	already	granted,	including Exemptions 11171	 through	

11174,	11176,	11177,	11062,	11109,	11112,	and	11213 and	as	recent	as	11857.

Sincerely,

Christian	T.	Tucci

President

tucci@cinematicaerospace.com /	(516)	308-1037

Cinematic	Aerospace,	Inc.

399	Conklin	Street

Suite	304

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

www.CinematicAerospace.com		(516)	308-1037 Page	21

APPENDIX	A - TECHNICAL	MANUALS	AND	SPECIFICATIONS

Petitioner	 submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contains

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	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	22

APPENDIX	B - COMMERCIAL	(MISSION/OPERATION)	PURPOSE	- FAA	

PREVIOUS	APPROVED	EXEMPTION	NUMBERS

Petitioner	 submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contains

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	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	23

APPENDIX	C – UAS	EQUIPMENT	- FAA	PREVIOUS	APPROVED	EXEMPTION	

NUMBERS

Petitioner submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contains

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	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	

EXEMPTION	NUMBERS

Petitioner	 submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contains

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	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	PICTURE	AND	TELEVISION	FLIGHT	OPERATION

MANUAL	- VERSION	v1.0

Petitioner	 submits	 this	 appendix/manual	 marked	 “CONFIDENTIAL,”	 as	 it contains

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	document	or	any	of	

its	contents	in	any	form	or	under	any	circumstances	without	prior	written	consent	

is	prohibited.

Submitted	under	separate	cover.