Airborne Media LLC Exemption Request Section 333 of the FAA Reform Act 1

June 8, 2015 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave. SE Washington, DC 20590 Scott Hinerfeld

- Principal C/O Airborne Media LLC 1035 Pearl Street, Suite 311, Boulder CO 80302 T: 720 878 5878 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23 (b); 14 C.F.R. 21; 14 C.F.R. 61.113 (a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103 (b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151 (a); 14 C.F.R. 91.203 (a) & (b); 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). Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the Reform Act) and 14 C.F.R. Part 11, Airborne Media LLC (herein referred to as “applicant”), operator of Small Unmanned Aircraft Sy stems (“sUASs”) equipped to conduct aerial videography and photography

for the motion picture, television, and commerc ial videography

industry for closed set filming, 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 outl ined herein or as may be established b y the FAA as required b y Section 333. As described more full y below, the requested exemption would permit the operation of small, unmanned sUAS under controlled conditions in the NAS that is 1) limited 2) predetermine d 3) controlled as to access. Approval of this exemption would thereb y enhance safety

and fulfill the Secretary

of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft s ys tems in the national airspace sy stem.” Section 333(c) of the Reform Act. The name and address of the applicant is: Airborne Media LL C Attn: Scott Hinerfeld 1035 Pearl Street, Suite 311 Boulder, CO 80302 Ph: 303 385 7286 Email: scott@airborne

- media.comAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 2

Regulations from which the exemption is requested: 14 C.F.R. 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 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 C.F.R. 91.151 (a) 14 C.F.R. 91.2 03 (a) & (b) 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) & (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 th e Secretary of Transportation to consider whether certain unmanned aircraft s ys tems may operate safel y in the national airspace sy stem (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 ty pes 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; • Operation of the UAS within visua l line of sight of the operator Lastl y, if the Secretary

determines that such vehicles “may operate safel y i n the national airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace s ys tem.” Id. § 333 (c) The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authorit y b y its terms includes exempting civil aircraft, as the term is d efined under §40101 of the Act 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 of a regulation prescribed under subsection (a) or (b) of this section or an y 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 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1). The applicant’s sUASs are rotorcraft, weighing 55 lbs. or fewer, including payload. They operate, under normal conditions at a speed of no more than 40 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously . They will operate onl y in line of sight and will operate only within a predetermined and closed off property

area under the permission of the property representative. Such operationsAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 3

will insure that the sUAS will “not create a hazard to u sers of the national airspace sy stem or the public” as per the Reform Act Section 333 (b). Given the small size of the sUASs involved, the restricted sterile environment within which they

will operate, and the fact that they will be flown b y an FAA licens ed aircraft pilot (Private Pilot’s L icense #3101173), the applicant falls squarel y within that zone of safet y (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence imme diately

. 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 contain ed 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 commercial videograph y / cinematography operations, the grant of the requested exemptions is in the public interest. Accordingl y, the applicant respectfully requests that the FAA grant the requested exemption without delay

. **I. AIRCRAFT DESCRIPTION** Airborne Media seeks an exemption to operate DJI s ys tems for compensation or hire within the NAS. The DJ I Phantom 3 Pro and DJI I nspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Stati on (GCS) utilizing electronic tablet or smart phone sy stems. The DJ I Phantom 3 Pro has a maximum gross weight of approximately

2 pounds 13 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximate ly 31 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJ I Phantom 3 Pro and DJ I Inspire 1UAs are equipped w ith four main rotors; driven by L ithium Poly

mer battery

powered electric motors. The DJ I Phantom 3 Pro and DJIInspire 1 UAS that will be operated b y #3101173 will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. II. EQUIVALENT LEVELOF SAFETY The applicant proposes that the exemption requested herein appl y 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 t o operations under the current regulatory structure because the proposed operations are conducted on closed off propert y under the permission of the property owner or property representative.Airborne Media LLC Exemption Request Section 333 of the FAA Reform Act 4

Proposed limitations and conditions to which applicant agrees to be bound when conducting commercial operations under an FAA issued exemption: • The PI C will hold a current ASEL (airplane, single engine, land) certificate, and either an FAA

- issued airman medical certificate, or a current U.S. driver’s license. Operation of the applicant’s sUAS will be limited to the applicant’s sole and primary pilot who meets these criteria. His certifi cation s are listed below:
Soren M . Jensen

- FAA issued ASEL certificate number: 3101173 U.S. I ssued driver’s license number: 10

- 175

- 0334 (Colorado) • The s UAS will weigh no more than 55 lbs. • Flights operations will be outside of five (5) nautical miles from an y airport reference point (ARP). I f asked to operate within five (5) miles of an airport, the applicant will contact the airport's manager and control tower with all flight plans, as well as the FAA through a norma l filing of a Form 7711

- 1 (or its equivalent) with the appropriate FSDO. Only upon approval of flight plans from all entities will we agree to, and conduct, an y operation within five (5) miles of an airport. • Flights will be operated within line of sight (un

- aided) of a pilot and/or observer. • Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 20% battery power reserve should that occur prior to the 20 minute limit, and no further flights shall be commenced on the same batteries unless they hold enough energy for a minimum of 5 minutes of flight time, or the minimum recommended b y the craft manufacturer.
• All operations shall be conducted in accordance with an ATO

- issued COA • Flights will be operat ed at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned. If a structure being filmed or photographed has a height that exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the highest point on that structure. • Minimum crew for each operation will consist of the sUAS Pilot, and the Visual Observer. • sUAS Pilot will be Pilot in Command (PI C). The PI C will have a minimum of 40 hours of flight time with the specific sUAS equipment the applicant operates. The experience of the PI C will be certified by the applicant through background checks and, if necessary , testing. • Applicant will maintain flight logs of all PI Cs it employ s, and provide full transparency to the F AA regarding the logs and records of these PI Cs, as per 14 CFR § 61.51(b ),Airborne Media LLC Exemption Request Section 333 of the FAA Reform Act 5

• Flights will be operated at a lateral distance of at least 100 feet from any i nhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation. • A briefing will be conducted in regard to the planned sUAS operations prior to each day ’s production activities. It will be mandatory that all personnel involved with the operational duties of th e flight within the boundaries of the safety perimeter be present for this briefing. • The operator will file an FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Offi ce. • The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may

be reduced to 30 feet based upon an equivalent level of safety determination. With the advanced permission of the relevant FSDO, operations at closer range can be approved.
• PI C and Visual Observer will have been trained in the operation of the specific sUAS equipment used by the applicant, and received up

- to

- date information on the particular sUAS to be operated. • The PI C designated for any operation will have at least a Class 2 medical certificate. • Visual Observer and PIC will at all times be able to communicate b y voice, radio, and/or text. • Written and/or oral permission from the relevant property holders or property representatives will be obtained. • All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, o r other appropriate governmental agencies. • If the sUAS loses communication with the PI C or loses its GPS signal, the sUAS will have the capability

to return to a pre

- determined location within the controlled propert y, and land autonomously

. • The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. • sUAS operations will not be conducted at night, as defined in 14 CFR § 1.1 • The sUAS will give way to any and all manned aviation operations and acti vities, at all timesAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 6

• The sUAS will not be operated from an y moving vehicle or device • Any incidents shall be reported to the FAA’s UAS Integration office within 24 hours. • During operations for closed

- set motion picture and television filming and production, the PI C will have a motion picture and television operations manual (MPTOM) as seen in this applications docket folder. **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certi ficates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular sUAS. In all cases, an anal ys is of these criteria demonstrates that the sUA S operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is 55 lbs. or less 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 aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already appl y to civil aircraft operated in connection with motion picture and television production, provide a greater degree of sa fet y t o the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastl y, application of these same criteria demonstrates that there is no credible threat to national se curit y posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. **14 C.F.R. § 45.23 (b). Marking of the Aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificatedAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 7

aircraft, the operator must also display on that aircraft near each entrance to 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 sUAS wi ll have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f), and The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required b y §45.29 (f) where the pilot, observer, and others working with th e sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued the following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 10167A. **14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in**  **Command.** The PI C will hold a current, FAA issued, ASEL (aircraft, single engine, land) certificate. PI C will be Soren Jensen (Private Pilots L icense #: 3101173), the chief pilot at Sky Sight LLC. Sections 61.113 (a) & (b) limit private pilots to non - commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations b y requiring the PI C operating the aircraft to have no less than 40 hours of flight t ime with the specific sUAS equipment the applicant operates. The experience o f the PIC will be certified b y the applicant through background checks and, if necessary , testing. The applicant will maintain flight logs of all qualified PICs it employees as pe r 14 CFR § 61.51(b ), and provide full transparency

to the FAA regarding the logs and records of these PICs. The PI C designated for an y operation will hold an FAA issued pilots license, and have at least a Class 2 medical certificate, or U.S issued driver’s license. 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 by

a PI C meeting the standards of the ap plicant (listed above) exceeds the present level of safet y achieved b y 14 C.F.R. § 61.113 (a) & (b). **14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.** The regulation requires that no person may operate a civil aircraft unless it is in airworthy conditi on. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. The applicant proposes that an equivalent level of safety will be provided by the use of the following safet y checklists prior to each flight in order to determine if the sUAS is in condition for safe flight:

 Aircraft: All adjustment points will be checked for tightness; all motors and propsAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 8 will be inspected; all wiring will be do uble

- checked; all sy stems will be powered up and checked for errors as per the flight s ys tems manuals.

 Battery : Confirmation will be made that batteries are full y charged and installed/connected properly

.

 Calibration: Pre

- flight motor/gy ro/compass calibr ation followed by confirmation of no errors with the flight and navigation sy stems.

 Transmitter: Confirm radio transmitter has sufficient charge, and is both working properl y and receiving telemetry from the sUAS; confirm all switches are in pre

flight m ode, and that a successful link has been established between the aircraft transmitter and onboard receiver.

 Confirm sufficient satellites are present for navigation system in the event of failsafe trigger

 Home point coordinates are confirmed recorded by navigation sy stem prior to take

- off

 Surroundings/Flight Area: Conduct one last visual inspection of the take

- off surroundings and area of airspace sUAS will be operating in. Confirm all people in the surrounding areas are associated with the operation being conducted.

 Take

- off Announcement: Before motors are started the PI C will announce to a designated Representative (person of authority) of the film crew that sUAS is ready to take

- off. Only

after the Representative has notified all persons within the surrounding areas, and confirmed to PI C that they have clearance to lift

- off, will the motors be started and the sUAS will conduct its operation. A mandatory

test flight will be conducted after any disassembl y/reassembly ; after replacement of an y motors or flight electronics; after an y pre - flight or in flight equipment errors that occur not resulting from environmental conditions. This will be done before commercial operation is commenced. All maintenance, overhaul, replacement, and inspections will be c arried out as per the manufacturers specifications by a knowledgeable and capable person with the experience necessary to ensure safe operation of the sUAS, and documented in the aircraft’s records. **(14 C.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) For which an Airplane or Rotorcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current ap proved airplane or RotorcraftAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 9

Flight Manual, approved manual material, markings, and placards, or an y combination thereof. The 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 capacit y to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the aircraft component flight manuals at the ground control point where the PIC flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 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

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed. In order to ensure consistent and safe operation, the PI C will perform pre

- flight inspection, maintenance, and test flights as described above with regards to 14 C.F.R. § 91.7 (a), as well as assess mission specific requirements (flight path, flight time, obstructions, landing and take

- of f hazards, aircraft performance, weather, etc) before commencing operation. **14 C.F.R. § 91.109: Flight instruction:** Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instructi on unless that aircraft has full y functioning dual controls. sUASs and remotely piloted aircraft, by

their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraf t via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of s afet y is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, and b y the size and speed of the aircraft. **14 C.F.R. § 91.119: Minimum safe altitudes** Section 91.119 establishes safe altitudes for operation of civil airc raft. 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 i s a helicopter and the exemption requests authority to operate at altitudes up to 400 feet AGL, or not more than 200 feet above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, th eAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 10

sUAS will never operate at higher than 400 feet AGLwith the exception that in circumstances where the sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest p oint on the structure. It will however be operated in a restricted area with securit y perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming a ctivity , all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 50 lbs. proposed herein and the lack of flammable fuel, an y risk associated wi th these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry . In addition, the low

- altitude operations of the sUAS will ensure separation between these small UAS operations an d the operations of conventional aircraft that must comply with Section 91.119. **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 the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved b y the operator, pursuant to the safet y check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditi ons**  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 fl y to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to fl y 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 no more than 20 minutes of powered flight. To meet the 30

- minute reserve re quirement in 14 C.F.R. § 91.151, sUAS flights would not be possible due to the reserve requirement being equal to the maximum flight time. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. The applicant believes that an exemption from 14 C.F.R. § 91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockhee d Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the smallAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 11

UAS, in a tightly

controlled area where onl y people and propert y 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. Additionally , the limitations created by this requirement for s UAS flights would essentially make null an y utility

for which the exemption will be granted. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 20% of battery power

— whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from any where in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. **14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft C ertification and Registration**  The regulation provides in pertinent part: (a) e xcept as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. (b) No p erson may

operate a civil aircraft unless the airworthiness certificate required b y paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or cr ew. The sUAS fully

loaded weighs no more than 50 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display

them on the sUAS. An equivalent level of safet y will be achieved by keeping these documents at the ground control point where the pilot fl yi ng 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 s ampl e of other exceptions includes exemption n os. 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 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 chap ter... ” and others sha ll inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance and inspections will be done in acc ordance with the sUAS Manufacturer's Manual, and will be performed by employees of the applicant following the guidelines and practices provided to us by the sUAS Manufacturer. 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 inAirborne Media LLC Exemption Request Section 333 of the FAA Reform Act 12

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately

and will be operating from no higher than 400 feet AGL. The PI C will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of an y m aintenance performed. Moreover, the PI C is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condit ion to provide the equivalent level of safet y. **III: Additional Views** Regarding Privacy: All flights will occur over private or controlled access property with the property representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. All flights will occur in accordance with any state or local laws regarding privacy

. Additionally , our company seeks to conform to privacy regulations what we believe are necessary , and imminent, if the UAS industry is to be accepted by

the general public, and therefore the motion picture and TV industries. Overall Safety and Benefits of Granting Exemption: The applicant believes that it’s sUAS equipment and personnel, in conjunction with the rules and regulations prescribed b y the FAA in the event of a successful exemption of the applicant, can provide a safe and valuable service to the film and television industries that offer increased sa fet y over current and past practices that use/used larger and more dangerous equipment, and in doing so, benefit the public as a whole. Our compan y is dedicated to working with the FAA to conform to current and upcoming regulation of the industry. We beli eve strict regulation of the UAS industry to be necessary if the technology

is to benefit the general public. Regulation will reduce unsafe practices, discourage improper uses, and improve public perception and safety

. **IV: Summary** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register: Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.1 09; 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) In summery , applicant seeks to operate commercially a small

- unmanned vehicle weighing less than 55 lbs. for a erial videography and photography for closed set filming in the motion picture, television, and commercial videograph y industry

.Airborne Media LLC Exemption Request Section 333 of the FAA Reform Act 13

Thank you for your consideration. Sincerel y, Scott Hinerfeld Principal

- Airborne Media LLC Airborne Media LLC affirms all information listed above to be true and binding upon the FAA’s findings of exemption regarding commercial operations of the specified UAS, until further notice of law or regulations decided by the FAA.