Great Dame Productions, LLC Tamara Warren 3600 Big Horn Trl Denton, Texas 76210 tamara@flyingeyeaerial.com

October20, 2015

U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14C.F.R. 45.23(b);14 CFR Part 21 ;14 CFR61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Siror Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Great Dame Productions, LLC, developerand operatorofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography forthe commercial video industry, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined 3) controlled asto access and 4) would provide safety enhancementsto the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the SecretaryofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

The name and address ofthe applicant is: Great Dame Productions, LLC Tamara Warren Ph: 404-345-8858 Email: tamara@flyingeyeaerial.com Address: 3600 Big Horn Trl, Denton, Texas, 76210



### 1Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14CFR61.113(a)&(b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR407 (a) (1) 14 CFR409 (a) (2) 14 CFR417 (a) & (b)

This exemption application is expresslysubmitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This lawdirects the Secretary ofTransportation to considerwhether certain unmanned aircraftsystems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following:

•The UAS's size, weight, speed, and operational capability;
• Operation ofthe UAS in close proximityto airports and populated
• Operation ofthe UAS within visual line ofsight ofthe operator.

Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c) (emphasis added) A

AApplicant interprets this provision to place the dutyon the Administratorto not only process applicationsfor exemptions under section 333, butforthe Administratorto craft conditions forthe safe operation ofthe UAS, ifit should be determined thatthe conditions setforth herein do notfulfill the statutory requirements forapproval.


### 2The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 oftheAct, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administratorfinds the exemption 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 ).

Great Dame Productions, LLC's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. Theywill operate only in line ofsight and will operate onlywithin the sterile area described in the Flight Safety Manual, attached as Exhibit B (hereinafter "the Manual"). Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." 8

Given the small size ofthe sUASs involved and the restricted sterile environmentwithin which theywill operate, the applicantfalls squarelywithin that zone ofsafety (an equivalent level of safety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also dueto the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristics and that operate with the limitations listed herein. These limitations provide forat least an equivalent or even higher level ofsafety to operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe movie and television filming operations conducted with conventional aircraft.

8 Reform Act Section 333 (b).



### 3These limitations and conditions to which Great Dame Productions, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/orobserver. 3. Maximum total flight timefor each operational flight will be 20 minutes. Flights will be terminated at25% battery power reserve should that occur priorto the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feetAGL or, not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator.

6. sUAS pilotwill be an FAA licensed airman with at least a sport or recreational certificate and a valid driver's license. The observerwill also hold a valid driver's license.

7. sUAS Pilotwill be Pilot in Command {PIC). Ifa pilot certificate holder otherthan the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC.

8. The UASwill only operate within a confined "Sterile Area" as defined in the Manual. Section C ofthe Manual requires the establishment ofa "Security Perimeter'' forthe flight operations area.

9. A briefing will be conducted in regard to the planned sUAS operations priorto each day's production activities. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be presentforthis briefing.

10. The operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office.

11. The operatorwill obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required by Section F ofthe Manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. (See Section B in the Manual Appendix B)

12. The operatorwill submit a written Plan ofActivities tothe FSDO three days before the proposed shoot as required in Section C ofthe Manual.

13. Pilot and observerwill have been trained in operation of UAS generallyand received upto-date information on the particular UAS to be operated as required.

14. Observerand pilotwill at all times be able to communicate by voice. 15. Written and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local lawenforcement, fire, orother appropriate governmental agencies.

17. Ifthe sUAS loses communications or loses its GPS signal, the UASwill have capabilityto return to a pre-determined location within the Security Perimeterand land.

18. The sUASwill have the capabilityto abort a flight in case of unpredicted obstacles or emergencies.



### 414 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meetsthe requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as setout in the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area ofoperation as is now done with conventional filming. The FAAwill have advance notice of all operations. These safety enhancements, which already applyto civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the UAS, dueto its size, speed ofoperation, location of operation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.

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

The regulation requires:

When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display
on that aircraft near each entranceto the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the UASwill have no airworthiness certificate, an exemption may be needed as the UASwill have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will be

5impossible. Theword "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the sUAV marked on its fuselage as required by§45.29 (f) where the pilot, observerand others working with the sUAV will see the identification ofthe UAS as "Experimental." The FAA has issued thefollowing exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14C.F.R. § 61.113 (a) 

### & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Becausethe UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safetyofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license ratherthan a commercial pilot's licenseto operatethis small UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level ofsafety provided by the requirements included in the Manual exceedsthat provided bya single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot asthe PIC exceeds the present level ofsafety achieved by 14 C.F.R. §61.113 (a) & (b).

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issuedforthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manualfor maintenance and use ofsafety check lists priorto each flight, as setforth in Sections C & D, an equivalent level ofsafetywill be provided.

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

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unlessthere is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.



### 6The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacityto carry such an item on the aircraft.

The equivalent level ofsafety will be maintained by keeping theflight manual atthe ground control point where the pilotflying the sUAS will have immediate accessto it. The FAA has issued thefollowing exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565,95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafetywill be provided as setforth in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation of flight.

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

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft hasfully functioning dual controls.

sUASs and remotely piloted aircraft, bytheir design do not havefully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided bythe fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. Safe simulation and practice flight will be carried out in controlled environments. All simulations will be carried outon a computer using the drone controls. Any practiceflying will take place in a safe environment, with no risk to human life below.

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

Section 91.119 establishes safe altitudes foroperation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than theminimums prescribed, provided the person operating the helicoptercomplies with any route oraltitudes prescribed for helicopters by the FAA. As this exemption is for a sUASthat is a helicopter and the exemption requests authority to operate ataltitudes upto 400 AGL, or not morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allowsuch operations. As setforth herein the UAS will never operate at higherthan 400 AGL. Itwill however be operated in a



### 7restricted areawith security perimeter, where buildings and people will not be exposed to operationswithouttheir pre-obtained consent.

The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owneror local officials. Because ofthe advance notice to the property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations as setforth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating ator below 500 AGL in the movie industry. In addition, the lowaltitude operations ofthe sUAS will ensure separation between these smaii-UAS operations and the operations ofconventional aircraftthat must complywith Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimetersetting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved bythe operator, pursuant to the Manual and Safety Checklist, confirming the altitude ofthe launch site shown on the GPS altitude indicator beforeflight.

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 underVFR conditions unless (considering wind and forecastweather conditions) there is enough fuel to fly to thefirst point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes."

The battery powering the sUAS provides approximately 25 minutes ofpowered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame for flight in daylightor nightVFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliancewith FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility forwhich the exemption will be granted.



### 8Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to20 minutes or25% of battery powerwhichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similarexemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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

The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following:
(1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unlessthe airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew.
The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS.

An equivalent level ofsafetywill be achieved by keeping these documents atthe ground control point where the pilotflying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43.

Given thatthese section and Part43 apply onlyto aircraftwith an airworthiness certificate, these sectionswill notapplyto the applicant. Maintenance will be accomplished bythe operator pursuantto the flight manual and operating handbook as referenced in the Manuai.(See Sections B, D and G) An equivalent level of safetywill be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land



### 9immediately and will be operating from no higherthan 400feet AGL. As provided in the Manual, the operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator isthe person mostfamiliar with the aircraft and best suited to maintain the aircraft in
an airworthy condition to provide the equivalent level ofsafety.

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:
Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151 (a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

### & (b) to operate commercially a small unmanned vehicle (551bs orless) in motion picture and television operations.
Approval ofexemptions allowing commercial operations ofsUASs in thefilm industrywill enhance safety by reducing risk. Conventional film operations, usingjetor piston power aircraft, operate at extremely low altitudesjustfeetfrom the subject being filmed and in extreme proximityto people and structures; and presentthe risks associated with vehicles that weigh in the neighborhood of4,0001bs., carrying large amounts ofjetA orotherfuel (140 gallons forjet helicopters shown below). Such aircraft mustfly to and from the film location. In contrast, a sUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustiblefuel carried on board. The sUAS is carried to the film set and notflown. The sUASwill carry no passengers or crew and, therefore, will not exposethem to the risks associated with manned aircraftflights.

The operation ofsmall UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are farsaferthan conventional operations conducted with turbine helicopters operating in close proximity tothe ground and people.

UASs Details: See Appendix C

Safety Features:
• Emergency "Return-To-Home" o At the beginning ofeach flight a home point is set. This home point is set in accordance with the manual to allowfor a safetakeoff and return. Should the pilot's control lose signal with the UAS

10Privacy or manually request a return, the UAS will return to the starting point.

All flights will occur over private orcontrolled access property with the property owner's prior consent and knowledge. Filming will be of peoplewho have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS in the commercial video production industry pursuantto the Manual appended hereto.

Great Dame Productions, LLC Tamara Warren

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