3209 Latham Drive 

Madison, WI 53713 

T 608.273.8458 

F 608.273.8456

U.S.	Department	of	Transporta1on,	Docket	Opera1ons		

West	Building	Ground	Floor,	Room	W12-140		

1200	New	Jersey	Avenue,	SE		

Washington,	DC	20590	

Re:Exemp1on	Request	Pursuant	To	Sec1on	333	(14	C.F.R.	11)	of	the	FAA	Reform	Act	of	2012	

Dear	Sir	or	Madam:	

This	applica1on	is	being	submiYed	on	our	own	behalf	without	legal	council	or	consul1ng	services.	

Tilt	Media	Inc.	is	a	fourteen	year	Wisconsin	based	S-Corpora1on	that	produces	TV	spots,	corporate	

video	and	web	videos	for	a	wide	ranging	clientele.	We	staff	five	full	1me	employees.	Tilt	Media	Inc.	is	a	

proven	leader	in	our	community	producing	high	defini1on,	broadcast	quality	TV	spots	and	video	for	

clients	such	as	PBS,	Wisconsin	DNR	and	ThermoFisher	among	many	others.	Tilt	Media	Inc.	has	an	award	

winning	and	experienced	crew	of	professionals	who	are	experts	at	crea1ng	high	defini1on	videos	in	a	

variety	of	situa1ons	and	loca1ons.	

We	are	wri1ng	pursuant	to	the	FAA	Moderniza1on	and	Reform	Act	of	2012	(the	Reform	Act)	and	the	

procedures	contained	in	14	C.F.R.	11,	to	request	that	Tilt	Media	Inc.,	an	owner	and	operator	of	small	

unmanned	aircra_,	be	exempted	from	the	Federal	Avia1on	Regula1ons	(FARs)	so	that	Tilt	Media	Inc.	

may	operate	its	small	unmanned	aircra_	system	(sUAS)	commercially	in	airspace	regulated	by	the	Federal	Avia1on	Administra1on	(FAA).	The	pe11oner	Tilt	Media	Inc.	is	also	filing	for	a	Cer1ficate	of	Waiver	

or	Authoriza1on	(COA).	In	the	event	that	a	COA	request	is	not	granted	I	would	ask	that	this	request	for	

exemp1on	s1ll	be	granted	with	a	condi1onal	use.

The	aircra_	that	Tilt	Media	operates	is	a	DJI	Phantom	II	P330Z	(US	ID#	NT0049970)	lightweight	(under	5	

pounds)	quadcopter	with	a	small	GoPro	camera	and	ouciYed	with	an	FPV	(first-person	view)	system	

and	updated	with	all	the	latest	DJI	Phantom	firmware.		The	latest	firmware	(V3.12)	added	a	No-Fly	Zone	

centered	on	the	White	House	and	extending	for	a	25	kilometer	(15.5	mile)	radius	in	all	direc1ons.	This	

addi1on	is	part	of	DJI’s	ongoing	work	with	regulators	to	ensure	safe	flight,	and	is	being	included	in	a	

scheduled	firmware	update.	DJI	is	con1nuing	to	update	its	no	fly	zone	list	to	include	sensi1ve	ins1tu-
1ons	and	na1onal	borders	in	compliance	with	local	regula1ons	and	helps	users	comply	with	the	FAA’s	

NOTAM	0/8326.		The	DJI	Phantom	II	is	renowned	as	a	stable,	safe	and	highly	maneuverable	sUAS	and	

they	are	highly	regarded	by	experts	in	the	field	of	unmanned	rotorcra_,	as	well	as	filmmakers.	

Tilt	Media	Inc.	will	u1lize	it's	sUAS	for	the	video	produc1on	industry,	though	given	the	DJI’s	stability	and	

maneuverability,	they	may	be	used	for	other	cinematography	such	as	real	estate,	agriculture	and	other	

uses.

Tilt	Media	Inc.’s	founder,	Rich	Rubasch,	lead	pilot	(PIC)	and	member	of	the	AMA	(Academy	of	Model	

Aeronau1cs)	and	the	AVUSI	(Associa1on	for	Unmanned	Vehicle	Systems	Interna1onal)	has	operated	

the	lightweight	DJI	Phantom	II	for	more	than	80	flight	hours	without	incident	and	would	like	to	formally	

request	permission	to	fly	this	sUAS	commercially	in	the	United	States	to	capture	aerial	cinematography,	

and	for	clients	who	request	surveying	or	for	educa1onal	uses.	Rich	has	flown	control-line	and	other	RC	

aircra_	for	years	as	a	hobbyist.		Rich	is	in	good	medical	health	and	sound	mental	health,	with	no	arrests	

or	felonies.	

Tilt	Media	Inc.’s	exemp1on	request	would	permit	its	opera1on	of	the	lightweight,	unmanned	(piloted	

by	remote	control)	and	compara1vely	inexpensive	sUAS	in	1ghtly	controlled,	closed	sets	and	in	very	

limited	airspace	under	300	feet.	All	flights	will	occur	over	private	or	controlled	access	property	with	the	

property	owner’s	prior	consent	and	knowledge.	Filming	will	take	place	on	sets	whose	owners	have	consented	to	filming	or	otherwise	have	agreed	to	allow	filming	in	the	area	where	filming	will	take	place.		

Predetermined,	specifically	marked	areas	of	opera1on,	cordoned	off	loca1ons	and	corresponding	enhancements	to	current	safety	controls	will	allow	Tilt	Media	Inc.	to	operate	within	current	safety	parameters.	With	a	team	of	3	dedicated	individuals	each	flight	is	conducted	with	Line	of	Sight	(LOS)	and	on	

site	crew	will	include	Pilot,	Navigator	and	SpoYer.		To	date,	Tilt	Media	Inc.	has	flown	countless	flights	at	

approved	Wisconsin	AMA	parks	and	its	own	property	and	has	done	so	safely	and	successfully.	

The	limita1ons	and	condi1ons	to	which	Tilt	Media	Inc.	agrees	to	be	bound	when	conduc1ng	commercial	opera1ons	under	an	FAA	issued	exemp1on	include:	

1.	The	sUAS	will	weigh	less	than	5	lbs	with	full	payload.		

2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.		

3.	Maximum	total	flight	1me	for	each	opera1onal	flight	will	be	<20	minutes.	Flights	will	be	terminated	

at	20%	baYery	power	or	less.	Safety	features	on	the	DJI	PHANTOM	II	include	auto	“return-to-home,”	an	

integrated	GPS	auto-pilot	system	that	offers	posi1on	holding,	al1tude	lock	and	stable	hovering	as	well	

as	a	complete	FPV	video	system	to	view	the	cameras	eye	view	at	the	controller	on	the	ground.			
4.	Pre-flight	inspec1on	would	include	checking	baYery	condi1on/level	in	both	the	transmiYer	and	UAS.	

The	binding/link	feature	will	not	let	the	UAS	start	if	communica1on	is	not	established.	Pre-flight	checks	

for	power	lines,	antennas	and	other	overhead	objects	would	be	performed.	Wind	condi1ons	would	be	

monitored	and	be	a	significant	factor	for	flying.	The	video	quality	suffers	in	winds	greater	than	12	miles	

per	hour	and	no	flights	would	occur	in	winds	greater	than	this.

5.	The	radio	frequency	of	the	DJI	PHANTOM	II	is	in	2.4	GHZ	range	and	the	FPV	camera	in	the	5.8	GHZ	

range.	Maximum	take-off	weight	is	less	than	1200g.	Max	Ascent/decent	speed	6	meters/sec.	Maximum	

flight	velocity	10	meters/sec.	

6.	Flights	will	be	operated	at	an	al1tude	of	no	more	than	300	feet	(AGL)	or,	not	more	than	200	feet	

above	an	elevated	placorm	from	which	filming	is	planned.		

7.	Minimum	crew	for	each	opera1on	will	consist	of	the	sUAS	Pilot,	the	Visual	Observer,	and	the	Navigator/Camera	operator.		

8.	The	UAS	will	only	operate	within	a	confined	“Sterile	Area.”		The	establishment	of	a	“Security	Perimeter”	will	be	set	for	the	flight	opera1ons	area.		

9.	A	briefing	will	be	conducted	in	regard	to	the	planned	sUAS	opera1ons	prior	to	each	day’s	produc1on	

ac1vi1es.	It	will	be	mandatory	that	all	personnel	who	will	be	performing	du1es	within	the	boundaries	

of	the	safety	perimeter	be	present	for	this	briefing.		

10.	The	operator	will	obtain	the	consent	of	all	persons	involved	in	the	filming	and	ensure	that	only	consen1ng	persons	will	be	allowed	within	100	feet	of	the	flight	opera1on,	and	this	radius	may	be	reduced	

to	50	feet	based	upon	an	equivalent	level	of	safety	determina1on.		

11.	Pilot	and	observer	will	have	been	trained	in	opera1on	of	UAS	generally	and	received	up-to-date	informa1on	on	the	par1cular	UAS	to	be	operated.		

12.	Observer	and	pilot	will	at	all	1mes	be	able	to	communicate	by	voice	and/or	text.		

13.	WriYen	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.		

14.	All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	or	city	jurisdic1ons,	including	local	law	enforcement,	fire,	or	other	appropriate	governmental	agencies.		

15.	If	the	sUAS	loses	communica1ons	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	return	to	a	

pre-determined	loca1on	within	the	Security	Perimeter	and	land.		

16.	The	sUAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	emergencies.	

The	sUAS	to	be	operated	hereunder	is	less	than	5	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger,	

carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates	exclusively	within	a	secured	area.	

Unlike	other	civil	aircra_,	opera1ons	under	this	exemp1on	will	be	1ghtly	controlled	and	monitored	by	

the	operator,	and	under	the	requirements	and	in	compliance	with	local	public	safety	requirements,	to	
provide	security	for	the	area	of	opera1on	as	is	now	done	with	conven1onal	filming.	The	FAA	will	have	

advance	no1ce	of	all	opera1ons	when	required.	Lastly,	applica1on	of	these	criteria	demonstrates	that	

there	is	no	credible	threat	to	na1onal	security	posed	by	the	UAS,	due	to	its	size,	speed	of	opera1on,	

loca1on	of	opera1on,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	inability	to	carry	a	substan1al	external	load.

Gran1ng	Tilt	Media	Inc.’s	request	comports	with	the	Secretary	of	Transporta1ons	(FAA	Administrators)	

responsibili1es	to	not	only	integrate	UASs	into	the	na1onal	airspace	system,	but	to	establish	requirements	for	the	safe	opera1on	of	such	aircra_	systems	[UASs]	in	the	na1onal	airspace	system	under	Sec1on	333(c)	of	the	Reform	Act.	

Further,	Tilt	Media	Inc.	will	conduct	its	opera1ons	in	compliance	with	the	protocols	described	herein	or	

as	otherwise	established	by	the	FAA.	For	the	reasons	stated	in	our	aYached	pe11on,	Tilt	Media	Inc.	respeccully	requests	the	grant	of	an	exemp1on	allowing	it	to	operate	lightweight,	remote	controlled	

UASs	within	the	na1onal	airspace	system	and	will	work	hand	in	hand	with	the	AMA	to	develop	safety	

guidelines	in	our	region	that	can	be	u1lized	by	the	sUAS	industry	for	similar	commercial	uses,	forthwith.	

We	believe	Tilt	Media	can	pave	the	way	in	our	area	for	the	safe	opera1on	of	sUAS	aircra_	in	an	ethical	

and	safe	manner	and	work	with	our	local	AMA	chapter	to	create	safety	programs	to	educate	the	community	at	large	about	the	value	and	benefit	of	sUAS	aircra_	for	a	variety	of	uses.

Thank	you.	

Respeccully	submiYed,	

Richard	Rubasch

President	/	Founder	

Tilt	Media	Inc.

3209	Latham	Drive

Madison,	WI		53713

O:	608-273-8458

M:	608-334-8458	

www.1ltmedia.com

AYachments:	

DJI	Phantom	II	User	Manual