June 10, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act 

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, OC Films, a video and film production company, 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 conditions outlined herein or as may be established by the FAA as required by 

Section 333.1

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that 

is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety 

enhancements to the already safe operations in the film and television industry presently using 

conventional aircraft. 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:

OC Films

Attn: Jorge Bicer

Ph: 949-288-6768

Email: info@ocfilms.com 

Address: 300 Spectrum Center Dr. Suite 400 - Irvine CA, 92618
June 10, 2015

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Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (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 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (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 Secretary 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 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’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of 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)2. 

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, that includes sUASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate.

2 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 requirements for approval.
June 10, 2015

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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 this title if the 

Administrator finds 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).

OC Films’s sUASs are 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 simultaneously. They will operate only 

in line of sight. Such operations will insure that the sUAS will “not create a hazard to users of 

the national airspace system or the public.”4

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

which they 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 the UASs 

and the restricted areas in which the relevant sUASs will operate, approval of the application 

presents no national security issue. Given the clear direction 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 environmental impacts, including reduced emissions associated 

with allowing UASs for movie and television operations, the grant of the requested 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 proposed operations represent a safety enhancement to the 

already safe movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions to which OC Films 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 of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 30 minute

limit.

4. Flights will be operated at an altitude of no more than 200 feet.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer,

and the Camera Operator.
June 10, 2015

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6.

7.

8.

9.

10.

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

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

All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

If the sUAS loses communications or loses its GPS signal, the UAS will have

capability to return to a pre-determined location within the Security Perimeter and

land.

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

emergencies.

Sincerely,

Jorge A Bicer

Owner

OC Films

 Jorge Bicer