August 6, 2015

Exemption No. 12367

Regulatory Docket No. FAA–2015–2035

Mr. Allen M. Gottfried

Electric Head LLC

15 Olivia Way

Jackson, NJ 08527

Dear Mr. Gottfried:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 18, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Electric Head LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, motion picture, and research.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Parrot BeBop.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Electric Head LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Electric Head LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Parrot BeBop 

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

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 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
May 18, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12­140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of

2012

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 ( the "Reform Act")

and the procedures contained in 14 C.F.R. 11, to request that Electric Head, LLC, owned and

operated by Allen M. Gottfried and as owners and operators of small unmanned aircraft

be exempted from the Federal Aviation Regulations ("FARs") listed below so that Electric Head,

LLC may operate its small unmanned aircraft/lightweight unmanned aircraft systems )"UAS")

commercially in airspace regulated by the Federal Aviation Administration ("FAA").

Primary uses will be low altitude aerial photography for use on websites, print pieces and HD

aerial videography for promotional and client use in a variety of productions but not limited to

Real Estate, Music Videos, Commercials, Independent Films, Construction, and more.

Allen Gottfried has operated and without incident a variety of UAS on many occasions for

non­commercial purposes. The UAS utilizes battery power, not combustible fuels. Flight time ranges

between five and twenty minutes depending on battery used. The UAS has GPS functionality to hover

in place as well as a return to home function in case of loss of contact with the radio. The firmware

and controller software will disable the UAS from taking off and also limit the UAS system from

operating within specific GPS preset no­fly zones.

Electric Head, LLC exemption request would permit its operation of lightweight, unmanned (piloted by

remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace.

Electric Head, LLC will conduct its operations in compliance with the protocols described herein or as

otherwise established by the FAA.

For the reasons stated below, Electric Head, LLC respectfully request the grant of an exemption

allowing it to operate lightweight, remote controlled UASs.
1. Contact Information:

Allen M. Gottfried

15 Olivia Way

Jackson, NJ 08527

Tel: 732­903­4418

email:

Allengot@gmail.com

2. The Specific Sections of Title 14 of the Code of Federal Regulations from Which We Request

Exemption is:

14CFR 21:

14 C.F.R. 45.23 (b):

14 CFR 61m113 (a) & (b):

14 C.F.R. 91, et seq.:

14 CFR 407 (a) (1): 14

CFR 409 (a) (2):

14 CFR 417 (a) & (b). U.S

Dep't of Trans.

3. The Extent of Relief Electric Head, LLC Seeks and the Reason It Seeks Such

Relief:

Electric Head, LLC submits this application in accordance with the Reform Act, 112 P.L.

95§§ 331­334, seeking relief from any currently applicable FARs operating in cinematic,

research and other flight operations within the national airspace system. The Reform Act

in Section 332 provides for such integration of civil unmanned aircraft systems into our

National airspace system as it is in the public's interest to do so. Our lightweight UAS meets

the definition of "small unmanned aircraft" as defined in Section 331 and therefore the

integration of our lightweight UAS is expressly contemplated by the Reform Act. We

would like to operate our lightweight UAS prior to the time period by which the Reform Act requires

the FAA to promulgate rules governing such craft.

The Reform Act guides the Secretary in determining the types of UASs that may operate

Safely in our national airspace system. Considerations include:

• The weight, size, speed and overall capabilities of the UAS:

• Whether the UAS will be operated near airports or populated areas: and,

• Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Electric Head,

LLC.
Our UAS utilizes four counter­rotating propellers for extreme balance, control and stability. It

weighs less than 5 pounds, including battery and all equipment. This small unmanned aircraft

is designed to primarily hover in place and operate at less than a 50 knot maximum speed. It is

capable of vertical and horizontal operation but operate only within the line of sight of the

remote control pilot.

Utilizing battery power, flights generally last between five and twenty minutes. We do not operate the

UAS with less than twenty five percent battery capacity.

Safety systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff

location if communication with the radio control pilot is lost. We generally do not operate the UAS near

airports or near populated areas unless contracted and cleared and authorized by such business. To

date, we have only operated the UAS in a non­commercial manner. Additionally, Electric Head, LLC

carries a $1­Million General Liability Insurance policy if in the unlikely case where any unforeseen

accidents should occur.

Our operation of this small unmanned aircraft will not "create a hazard to users of the national

airspace system or the public." 112 P.L. 95 § 333 (b). Given the small size and weight of the

UAS, combined with its operation in designated and well­controlled fly zones, which falls within

Congress's contemplated safety zone when it promulgated the Reform Act and the

corresponding directive to integrate UASs into the national airspace system. Indeed, our UAS

will not pose any threat to the general public or national security.

The FAA has the authority to issue the exemption sought by Electric Head, LLC pursuant to

the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

4. How this Request Will Benefit the Public As A Whole:

Granting this exemption request furthers the public interest. Congress has already pronounced

that it is in the public's interest to integrate commercially flown UASs into the national airspace

system, hence the passing of the Reform Act. Electric Head, LLC conduct research into safe UAS

operations every time it flies its UAS. Flight data, visual inspections, recorded observations and flight

analyses are compiled to further enhance current safety protocols. Allowing us to log more flight time

directly relates to our research and our ability to further enhance current safety measures.

Our UAS is battery powered and creates no emissions. If our UAS crashes there is no fuel to ignite

and explode. The impact of our lightweight UAS is negligible when compared to

a full size aircraft.

Granting this request will also allow small business owners, independent filmmakers and

homeowners to be able to afford high quality aerial images and video that they would otherwise

have no access to due to several factors, cost being the biggest.
5. Reasons Why Electric Head, LLC Exemption Will Not Adversely Affect Safety

• Our UAS weighs less than 5 pounds complete with all mounted equipment and

battery:

• We only operate our UAS below 400 feet:

• Our UAS only operates for 5­20 minutes per flight:

• We land our UAS when it reaches 25% battery power:

• Our remote control pilot operates the UAS by line of sight:

• Our remote control pilot has video backup and GPS override should sight of the

UAS be lost.

Additional Notes:

The potential loss of life is diminished as no people on board.

There is no fuel on board a UAS and thus the potential for fire or explosions is greatly

diminished.

The small size and extreme maneuverability of our UAS allows our remote control pilot to

avoid hazards.

6. Summary:

A. 14 C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The

size, weight and enclosed operational area of Electric Head, LLC UAS permits exemption

from Part 21 because Electric Head, LLC

UAS meets an equivalent level of safety pursuant to Section333 of the Reform Act. The FAA

is authorized to exempt aircraft from the airworthiness certificate requirement under both the

Act (49 U.S.C. § 44701 (f) and Section 333 of the Reform Act. Both pieces of legislation

permit the FAA to exempt UASs from the airworthiness certificate requirement in

consideration of the weight, size speed, maneuverability and proximity to areas such as

airports and dense populations. Electric Head, LLC UAS meets or exceeds each of the

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As

no such certificate will be applicable in the form contemplated by the FARs, this Regulation

is inapplicable.
14 C.F.R § 91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or

passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of

safety will be achieved by maintaining a manual at the flight operations center. The FAA has

previously issued

exemptions to their regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, 10167A, 10602, 10700 and 32827.

14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Electric Head, LLC

utilizes

electronic global positioning systems and internal gyroscopes to provide spatial

coordination.

14 C.F.R. § 91.203 (a)) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The equivalent level

of safety will be achieved by maintaining such certifications and registrations at Electric Head,

LLC flight operations center.

B. 14 C.F.R § 45.23: Marking of the Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain

specifications. Electric Head, LLC UAS is, by definition, unmanned. It therefore does not have a

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two­inch lettering is

difficult to place on such small aircraft. Regardless, Electric Head, LLC will mark its UAS in the

largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14

C.F.R. § 45.29(f) so that the pilot, technician, spotter and others working with the UAS will see the

markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos.

8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R.§§

61.113 (a) & (b) private pilots are limited to non­commercial operations. Electric Head, LLC can

achieve an equivalent level of safety as achieved by current regulations because Electric Head,

LLC UAS does not carry any pilots or passengers. Furthermore, while helpful, a pilot license will

not ensure remote control piloting skills. The risks attendant to the operation of Electric Head, LLC

UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.§ 61,

et seq. Thus, allowing Electric Head, LLC to operate its UAS

with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R.

§ 61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

helicopters to be operated at lower altitudes in certain conditions. Electric Head, LLC will never

operate at an altitude greater than 400 AGL. Electric Head, LLC will, however, operate its UAS in

cordoned off areas with security perimeters, providing a level of safety at least equivalent to those in
relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of Electric

Head, LLC UAS, an equivalent level of safety will be achieved.

E. 14 C.F.R. 91.405 (a) (2); 417 (a) & (b): Maintenance Inspections.

The above cited Regulations require, amongst other things, aircraft owners and operators to

"have aircraft inspected as prescribed in subpart E of this part and shall between required

inspection, except as provided in paragraph © of this section, have discrepancies repaired as

prescribed in part 43 of this chapter...."

These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will

not apply to Electric Head, LLC should its requested exemption be granted. Electric Head, LLC

conducts as extensive maintenance program that involves regular software updates and curative

measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

F. Summary

Electric Head, LLC seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H;

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(b); 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; C.F.R. § 91.151

(a); 14 C.F.R. §§ 91.203(a) and (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. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) & (b) to commercially

operate its lightweight unmanned aircraft in motion picture or photography operations and to

conduct its own research. Granting Electric Head, LLC request for exemption will reduce current

risk levels and thereby enhance safety. Currently motion picture image capture relies primarily on

the use of larger aircraft running combustible fuel. Electric Head, LLC aircraft does not contain

potentially explosive fuel, is smaller, lighter and more maneuverable than conventional motion

picture aircraft. Electric Head, LLC operates at lower altitudes and in controlled airspace. Electric

Head, LLC has been analyzing flight data and other information in compiling novel safety protocols

and the implementation of a flight operations manual that exceeds currently accepted means and

methods of safe flight. There are no people on board Electric Head, LLC UAS and therefore the

likelihood of death or serious bodily injury is significantly limited. Electric Head, LLC operation of

its UAS, weighing less than 5 pounds and travelling at speeds lower than 50 knots in cordoned off

areas will provide at least an equivalent level of safety as that achieved under current FARs.

Accordingly, Electric Head, LLC respectfully requests that the FAA grant its exemption request

without delay. The FAA has the authority to issue the exemption sought by Electric Head, LLC

pursuant to the Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act").

In closing, Electric Head, LLC would like to state that it would be very easy to ignore the FAA

and operate a UAS commercially without applying for any consideration from them. We have

seen and spoken with several people who are already doing so. We hope the simple fact that

someone such as ourselves who operate a very small business and will be operating a UAS on

a very small scale is applying for this exemption shows how serious we are about safety and

doing things properly. Thank you for your time and consideration.
Respectfully submitted,

Allen M. Gottfried

Owner, Electric Head, LLC

www.electricheadonline.com