Jonathan B. Hill

T: +1 202 776 2725 jhill@cooley.com

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, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Summary Processing: Exemption Request for Helicopters West, Inc. Under

Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. §§ 61.113(a) and (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b).

Dear Sir or Mada m:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Helicopters West, Inc. (“ Helicopters West ”) operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct commercial flights for aerial photography and filming (hereinafter “the Purpose”), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the cond itions outlined herein or as may be established by the FAA in an exemption granted under either Sect ion 333 or 49 U.S.C. § 44701(f)

. Helicopters West will accept the conditions set forth in Exemptions Nos. 11062 and its progeny Nos. 11063 through 11067, 1 1080, 11150

, 11158 , 11160 , 11161 , and 11172 (“the Similar Exemptions). We ask for summary approval of this exemption request

.

As with the approval of the Similar Exemptions, 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.

The name and address of the applicant is:

Helic opters West Aerospace LLC

Attn: John D. Sarviss

495 Aviator Lane Tuscumbia, Alabama 35674

Ph. : 661

- 810

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- 7899 WWW.COOLEY.COM Regulations from which the exemption is requested:

14 C.F.R. § 61.113(a) and (b)

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. § 407(a)(1)

14 C.F.R. § 409(a)(2)

14 C.F.R. § 417(a) and (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretar y of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretar y is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

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

• Operation of the UAS in clos e 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 Secret ary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added) 1

.

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform Act, expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under § 40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthine ss certificate.

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

- 44716 of the Transportation Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f). See

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

Helicopters West is a startup company that will enter the movie and television, aerial photography for television and film industry. Helicopters West UASs a re rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane

1 Applicant interprets this provision to place the 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 r equirements for approval.February 18, 2015 Page Three

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- 7899 WWW.COOLEY.COM simultaneously. They will operate at al titudes of no more than 400 feet, as further explained, and only in line of sight. They will operate only within the sterile areas as described in the Helicopters West Flight Operations Manual

.

In support of this application, Helicopters West is submittin g, with a request for confidentiality as shown, the following manuals (hereinafter “the Manuals”) 2 :

• 14 Channel Computer S ystem 14 SG Instruction Manual, Exhibit 1 (Public)

• Helicopters West LLC sUAS Flight Operations Manual (“FOM”), Exhibit 2 (Confidential)

• Helicopters West DJI INSPIRE 1 sUAS Aircraft Flight Manual , (Exhibit 3 ) (Confidential)

• Helicopters West SkyJib 8 sUAS Aircraft Flight Manual , (Exhibit 4 ) (Confidential)

Operations in compliance with these manuals will insure that the sUAS will “not creat e a hazard to users of the national airspace system or the public” 3 and that the aircraft will operate in compliance with the conditions set forth in this application.

Given the small size of the sUASs involved and the restricted environment within which

t hey will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of th e UASs, the restricted areas in which the relevant sUASs will operate and the fact that aircraft will be flown by pilots holding at least a FAA private pilot license, approval of the application presents no national security issue. Given the clear directi on in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in env ironmental impacts, including reduced emissions associated with allowing battery powered UASs for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant of the

reque sted exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the propo sed operations represent a safety enhancement to the already safe movie and television filing operations conducted with conventional aircraft

. 4

2 Applicant submits the Manuals, marked “CONFIDENTIAL”, as they contains propriety business information that is not released to the public and is protected under t he Freedom of Information Act, 5 U.S.C. § 553, etc.

3 Reform Act Section 333(b).

4 These conditions are reproduced from Similar Exemptions (11062 through 11067 , 11080 , 11150

, 11158
11160, 1 1161 and 11172 ).February 18, 2015 Page Four

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- 7899 WWW.COOLEY.COM Helicopters West notes that has requested that a Certificate of Authorization (COA) not be required for flight a t or below 400 feet AGL, in Class G airspace and outside of 5 nautical miles from the geographic center of airport where a letter of agreement has not been entered with the airport management.

These limitations and conditions to which Helicopters West agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UA must weigh less than 55 pounds, including energy source(s) and equipment. Operations will be limited to the aircraft described in the proprietary Manual s:

2. The UA may not be flown at a speed exceeding a ground speed of 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL) as indicated by the procedures specified in the Operators Manuals. All altitudes
report ed to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issu ed medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. The op erator will be bound by and follow the Manuals as accepted by the FAA. Any additional requirements identified in the final conditions for this Exemption will be added

to the Manuals. The Manuals will be maintained and made available to the

Administrator upon request. If a discrepancy exists between the conditions and limitations in the final exemption and the procedures outlined in the Manuals, the conditions and limitations of the Exemption will take precedence and will be followed. Otherwise, the oper ator will follow the procedures as outlined in its Manuals

. The operator will update or revise its Manual. It will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request.

The operator will also present updated and revised documents if it petitions for extension

or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the ope rator will petition f or amendment to their exemption. The operator will contact the FAA’s UAS Integration Office (AFS

- 80) with questions arising regarding updates or revisions to the Manual.

7. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will not operate until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized,February 18, 2015 Page Five

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- 7899 WWW.COOLEY.COM will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characte ristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the Manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be

added to the Manuals.

9. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unava ilable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the Manuals. At a minimum, the following must be included in the Manual:

a. Actuators / Servos

b. Transmission (single ro tor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used) j. Any other components as determined by the operator

10. The PIC will possess at least a private pilot certificate and at least a current third

- class

medical certificate. The PIC will also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his/her pilo t certificate.

11. Prior to operations conducted for the Purpose, the PIC will have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a s imilar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations will be used to satisfy this requirement. Training, proficiency, and experience

- building flights may also be cond ucted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations

will be considered non

- participants, and the PIC w ill operate the UA with appropriate

distance from non

- participants in accordance with 14 C.F.R. § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, exper ience

- building, and take

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- 7899 WWW.COOLEY.COM off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off and landing currency fligh ts all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator’s

manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the Purpose, a flight demonstration, administered by

a n operator

- approved and

- qualified pilot will be successfully completed and

documented. This documentation will be available for review upon request by the

Administrator. Because the knowledge and airmanship test qualifications will be developed by the o perator, and there are no established practical test standards that support a jurisdictional FAA Flight Standards District Office (FSDO) evaluation and approval of company designated examiners, the Operator will conduct these tests in

accordance with the M anual.

The UA will not be operated directly over any person, except authorized and consenting personnel necessary for the Purpose, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

15. Flight operations m ust be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a) Barriers or structures are present that sufficiently p r otect nonparticipating persons from the UA and/or de b ris in the e ve n t of an acci d ent. The operator m ust

e nsure that nonparticipating persons re m ain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operatio n s m ust cease im m ediately and/or;

b) The air c raft is oper a ted n ear ves s els, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted per m ission

and the PIC has m ade a safety assess m ent of the risk of operating closer to those objects and deter m ined that it does n ot prese n t an undue hazard, and;

c) Operations nearer to t h e PIC, VO, operator trainees or essential persons do
not present an u ndue hazard to those p ersons per § 9 1 .119(a).

All operati o ns shall b e conducted o v er pri v ate o r contr o lle d

- access pro p erty with

per m ission from the property owner/controller or authorized representative.February 18, 2015 Page Seven

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- 7899 WWW.COOLEY.COM Per m ission from property owner/co n t roller o r author i zed represent a tive w ill b e obt a i n ed for each flight to be conducted.

See , Exemptions 11170, 11172 and 1117 for proposed language.

16. Prior to any flight Operator will only be required to obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) for flights that are conducted at heights greater than 400 AGL; in ot her than Class G airspace; and closer than 5 miles from the geographic center of a non

- towered airport, without a letter of agreement with the airport manager. If requested, Operator will provide telephonic advanced notice to

an ATO or file a NOTAM for an y flight not requiring a COA.

17. If the UAS loses communications or loses its Global Positioning System (GPS) signal, the UA will be programmed to return to a pre

- determined location within the security perimeter and land or be recovered in accordance with t he Manual.

18. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the Manual.

19. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first.

20. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, subpart C. Markings will be as la rge as practicable.

21. The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These proce dures will be

added to the Manual.

22. Each UAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

23. The operator will develop UAS technician qualification criteria. These criteria will be

added to the Manual.

24. The preflight inspec tion section in the Manual will be amended to include the following requirement: The preflight inspection will account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection

sections of the Manual.

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.February 18, 2015 Page Eight

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- 7899 WWW.COOLEY.COM 26. The documents required under 14 C.F.R. §§ 91.9 and 91.203 will be available to the PIC at the ground control station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official
upon request.

27. The UA will remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

28. UAS operations will not be condu cted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be undertaken.

29. The UAS will not be operated by the PIC from any mov ing device or vehicle.

30. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

31. The UA will not operate in Class B, C, or D airspace without written approval from the

FAA. The UA will not operate within 5 nautical miles of the geographic center of a non

towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, an d the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request.

32. Any 1) incident, 2) accident, or 3) flight operation t hat transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS

- 80) within 24

hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov . Further flight operations will not be conducted until the incident, accident, or transgression is reviewed by A FS

- 80 and authorization to resume operations is provided.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 C.F.R. including, but not limited to, parts
45, 47, 61 , and 91.

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

Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a pri vate pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is control led and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safetyFebruary 1 8, 2015 Page Nine

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- 7899 WWW.COOLEY.COM provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certif icate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as reque sted with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. § 61.113(a) and (b). The FAA has granted exemptions for private pilots to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and

11080.

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 helic opter 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 oper ations. As set forth herein, except for the limited conditions stated in the Manual and in condition #3, page 3, the UAS will never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, 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 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 Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operati ons is far less than those presently presented with 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 small

- 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, 11063, 11064, 11065, 11066, 11067 and 11080.

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

This regul ation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS in at least on e operating mode will not have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

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 fuelFebruary 18, 2015 Page Ten

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- 7899 WWW.COOLEY.COM 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 40 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would be limited to approximately 10 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 longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 C.F.R. § 91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without co mpliance 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.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens fir st. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemp tions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in complianc e with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating han dbook as referenced in the Flight Operations and Procedures Manual (FOPM) attached as confidential Exhibit 2. (See) 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 areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the UAS is in working order prior to initia ting flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.February 18, 2015 Page Eleven

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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. §§ 61.113(a) and (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a) (1); 91.409(a)(2); 91.409(a)(2) and 91.417(a) and (b) to operate co mmercially a small unmanned vehicle (55 lbs. or less) in motion picture and television operations.

Approval of exemptions allowing commercial operations of sUASs for filming for motion picture and television work will enhance safety by reducing risk. Con ventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighbo rhood 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 sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually a ll of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the target area and not flown. The sUAS 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, weighting less than 55 lbs., conducted in 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 inspections and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the gro und and people or the use of people to climb the structures to conduct the inspection.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Inspection be of inanimate objects in areas where the owners and/or operator will have consented to observation/ filming or otherwise have agreed to be in the area where inspection will take place.February 18, 2015 Page Twelve

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- 7899 WWW.COOLEY.COM 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 applicant’s UAS for the Purposes outlined herein and are consistent with exemptions already granted, including the Similar Exemptions (11062 through 11067, 11080, 11150

, 11158 11160,11161 and 11172 ).

Sincerely,

Jonathan B. Hill Cooley LLC

Counsel for He licopters West

, Inc.

John McGraw John McGraw Aerospace Consulting, LLC Agent for Helicopters West , Inc.

cc: James Williams Robert Pappas

Jake Troutman Dean Griffith, Esq. Thuy H. Cooper

114045544