January 19, 2016

U. S. Department of Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11

of the

Federal Aviation Regulations from: 14 CFR 45.23 (b); 14 CFR 21 ; 14 CFR

61.113(a) and (b); 14 CFR 61 .113 (a) & (b); 91 .7 (a); 91.9 (b) (2); 91 .1 03;

91 .109; 91.119(c); 91 .121 ; 91 .151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409 (a)(1) and (2); 91.417(a) and (b).

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 , Meldahl an operator of Unmanned Aircraft

Systems ("UASs") for aerial photography, film , survey, and search and rescue, hereby

applies for an exemption from the Federal Aviation Regulations ("FARs") to allow

commercial operation of its UASs.

 To date, the FAA granted numerous exemptions to UAS operators, including

Astraeus Aerial, Team 5 LLC, Alan Purwin, and Helinet Aviation Services.

 Meldahl’s requested exemption would permit the operation of small, unmanned

UAS under controlled and sterile airspace that is: (i) limited , (ii) predetermined , (iii)

subject to controlled access, and (iv) provide greater safety in connection with aircraft

operations. As established by the exemptions already granted by the FAA, approval of

Meldahl’s exemption would 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:

Bryan Meldahl

Ph: 425.772.3885

Email: pcab2004@gmail.com

12303 Harbour Pointe BLVD O201

Mukilteo, Wa 98275

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 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.

 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 §401 01 of the Act, that includes UASs, from the requirement that

all civil aircraft must have a current airworthiness certificate.

UASs operated by Meldahl weigh less than 55 pounds, including the payload

(i.e. camera, lens, and gimbal). They operate at speeds of no more than 40 knots, can

hover, and can simultaneously move vertically and horizontally. Meldahl will only

operate its UASs in line of sight and will operate only within the sterile area. Such

operations will insure that the UAS will "not create a hazard to users of the national

airspace system or the public."

 Meldahl seeks an exemption to operate the 3DR Iris, DJ1 Spreadwings S1000,DJI 

Phantom 2 and DJI Inspire 1 model UAS for compensation or hire within the NAS. Such 

activities include, but are not limited to, aerial survey, aerial photography and film , and 

assist search and rescue operations in remote areas. Each UAS has a maximum gross 

weight under 10 pounds, maximum speed of 49 mph (approximately 42 knots), and a run 

time of approximately 30 minutes. A copy of the operating handbook for each aircraft will be 

submitted with this exemption request.

 Each UAS operated by Meldahl 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.

 Given the small size of Meldahl’s UASs and the restricted sterile environment

within which they will operate, Meldahl’s UAS operations adhere to the Reform Act's

safety requirements. Additionally, due to the size of the UASs and the limited areas in

which they will operate, approval of this application presents no national security issues.

Based on the substantial level of safety surrounding the proposed operations, and the

significant public benefit (enhanced safety), reduction in environmental impacts

(reduced emissions and noise), the grant of the requested exemption is in the public

interest. Accordingly, Meldahl respectfully requests that the FAA grant the requested

exemption without delay.

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Aircraft and equivalent level of safety

 The applicant proposes that the exemption requested apply to civil aircraft that

have the characteristics and that operate with the limitations listed. 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 aerial photography and aerial filming for movie and

television filming operations conducted with conventional aircraft.

 These limitations and conditions to which Meldahl agrees to be bound when

conducting commercial operations under an FAA issued exemption include:

1. The UAS 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 400 feet AGL

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

Observer, and the Camera Operator.

6. UAS pilot will be an FAA licensed airman with at least a private pilot's

certificate and third class medical. The observer will hold at least a third class

medical.

7. UAS Pilot assumes all duties and responsibilities as Pilot in Command (PIC).

8. The UAS will only operate within a confined "Sterile Area". Security will be

performed by the operator and designated security personnel.

9. A briefing will be conducted in regard to the planned UAS operations prior to

each day's production activities. It will be mandatory that all personnel who will

be performing duties within the boundaries of the safety perimeter be present for

this briefing.

10. For photo and film missions, the operator will obtain the consent of all

persons involved in the mission 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.

11 . For photography and photo missions, the operator will submit a written Plan

of Activities to the FSDO three days before the proposed mission.

12. Pilot and observer will have been trained in operation of UAS generally and

received up-to-date information on the particular UAS to be operated.

13. ALL crew members will at all times be able to communicate by ONLY voice

communications as to ensure all crew members maintain a visual contact with

the UAS at ALL TIMES.

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

obtained.

15. 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.

16. If the UAS 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.

17. The UAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

*For emergency assistance with State and Government Agencies, such as

assisting in search efforts, we ask that we be exempt from the 72 hour plan of

activities notice.

UAS Crew Requirements:

 UAS Pilot in Command must:

 1. Hold at least a FAA Private Pilot with current 2nd class medical

 2. Have logged a minimum of 100 takeoff and landing cycles and 25

 hours of total time as a UAS rotorcraft pilot and at least 10 hours

 logged as a UAS pilot with a similar UAS type (single blade or

 multirotor); a minimum of 5 hours as UAS pilot with the make and

 model of UAS to be utilized for operations under the exemption

 and 3 take offs and landings in the preceding 90 days; (training

 and currency documentation will be submitted with plan of

 activities)

 3. Received training in the safe operation of the UAS to be operated.

 Training will include:

 a. Normal and emergency modes of operation

 b. Familiarization with the operation manual published by the

 UAS manufacturer.

 c. Types of maneuvers to be performed during operations

 including safe operation in relation to persons, property and

 applicable airspace using the actual UAS or manufacturers

 simulation software

Camera Operator must:

 1. Be familiar with the operation manual published by the UAS

 manufacturer.

 2. Receive training in the safe operation of the camera I gyro systems

 operated onboard the UAS. Training will include:

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 a. Proper method of loading, rigging, or attaching the camera

 mount, lighting, and any external equipment

 b. Types of maneuvers to be performed during operations

 c. Safe operation in relation to persons, property and

 applicable airspace.

 d. Receive training on basic VFR weather minimums outlined

 in 14 CFR 91 .155

In a dual control configuration, the Camera Operator will not operate the master

controller.

Observers must:

 1. Hold at least a third class medical

 2. Be familiar with the use of VHF I FM radio communication.

 3. Have received training on the National Airspace System 14 CFR 71 and

 the basic VFR weather minimums outlined in 14 C.F.R. 91.155.

The Plan of Activities

The Plan of Activities must include the following:

 1. Dates and times for all flights;

 2. Name and phone number of the person responsible for the photography I

 filming event;

 3. Name and phone number of the person responsible for the aircraft;

 4. Make, model and serial number and/or registration number of all UAS t to

 be used;

 5. Name and certificate number, if applicable, of all crewmembers to be

 utilized in the event including copies of FAA Medical Certificates,

 endorsements, and flight logs to indicate currency;

 6. A statement that the Waiver Holder has obtained permission from property

 owners and/or local governmental officials to conduct the event;

 7. Signature of Waiver Holder or representative;

 8. 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 minimum altitudes essential to accomplish the operation.

Briefing for Photography and Film Missions

 Meldahl and the event representative will conduct a verbal and written briefing for

the members involved , including emergency, if applicable, and security personnel. This

briefing will be conducted prior to each day's UAS activities and will include the

following items.

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 1. Authorization UAS flight operations, Plan of Activities, special provisions and any

 additional provisions issued by the Flight Standards District Office having

 jurisdiction over the photo I filming area.

 2. Radio communications.

 3. Takeoff procedures.

 4. Aviation activities to be conducted during the event.

 5. Approach and landing procedures.

 6. Alternate landing zone in the event of emergency or security breach

 7. Recall procedures.

 8. Emergency procedures.

 9. Possible risk to personnel that are involved.

 10. Control of non-participating persons.

 11. Location of boundaries or deadlines, man-made or natural, readily visible to the

 participants.

 12. Local governmental limitations, restrictions, or any special circumstances, such

 as noise sensitive areas, time of day restrictions or changes in operating

 procedures.

Security

 The exclusion from the flight operations area of unauthorized persons, vehicles

or aircraft will be enforced by designated event personnel, private security officers or

sworn law enforcement officers at the direction of Meldahl.

 Meldahl or a designated representative will halt flight operations in the event

unauthorized persons, vehicles or aircraft enter the flight operations area.

 A predetermined abort signal will be used to halt flight operations should a

breach of perimeter security occur, or for any other reason in the interest of safety.

 Alternate UAS landing sites will be made available prior to the start of the event.

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)

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14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

 Subpart H, entitled Airworthiness Certificates, 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 UAS. In all cases, an analysis

of these criteria demonstrates that the UAS 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 UAS to be operated hereunder is less than 55 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 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 apply to civil aircraft operated in connection with motion picture and television

production, provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that

there is no credible threat to national security posed by the UAS, 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 certificated 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

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 words "limited," "restricted," "light-sport," "experimental," or "provisional,"

 as applicable.

 Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which

the word Experimental" can be placed. Given the size of the UAV, two-inch lettering will

be impossible. The word "Experimental" will be placed on the fuselage in compliance

with §45.29 (f).

 The equivalent level of safety will be provided by having the UAV marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the

UAV will see the identification of the UAS as "Experimental." The FAA has issued the

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167 A.

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

 Sections 61.113 (a) & (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 private 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 UAS is remotely controlled with no living thing on board. The area

of operation is controlled and restricted, and all flights are planned and coordinated in

advance. The level of safety provided exceeds that provided by a single individual

holding a commercial pilot's certificate operating a conventional aircraft. The risks

associated with the operation of the UAS are so diminished from the level of risk

associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the UAS as requested with a private pilot as the PIC exceeds the

present level of safety achieved by 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 condition. 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. Given the size of the aircraft and the requirements contained in the

Manufacturers Operating Manual for maintenance and use of safety check lists prior to

each flight, an equivalent level of safety will be provided .

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

 Section 91.9 (b) (2) provides:

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 No person may operate a U.S.-registered civil aircraft ...

 (2) For which an Airplane or Rotorcraft Flight Manual is not required by

 §21.5 of this chapter, unless there is available in the aircraft a current

 approved airplane or Rotorcraft Flight Manual, approved manual material,

 markings, and placards, or any combination thereof.

 The UAS, 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 capacity to carry such an item on the aircraft.

 The equivalent level of safety will be maintained by keeping the flight manual at

the ground control point where the pi lot flying the UAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737,8738,9299, 9299A, 9565,95658, 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. The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances

and aircraft performance data before initiation of flight.

14 C.F.R. §91.1 09: Flight instruction:

 Section 91.103 provides that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls.

 UASs 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 aircraft 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 safety can be achieved as neither a pilot nor passengers will be

carried in the aircraft in addition to the small size and low speed of the aircraft.

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 helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter

and the exemption requests authority to operate at altitudes up to 400 AGL. As set forth

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herein, except for the limited conditions stated in the Manual, the UAS will never

operate at higher than 400 AGL. It will however be operated in a restricted area with

security 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, 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 or local officials. Because of the advance notice to the

property owner and participants in the filming activity, 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 551bs. proposed herein and the lack of

flammable fuel, any risk associated with 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 UAS will ensure separation

between these smaii-UAS operations and 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 UAS 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 by the operator, pursuant to

the Manual and Safety Check list, by receiving altitude information via a digitally

encoded telemetric data feed, which downlinks from the aircraft to a ground-based 

onscreen display. This altitude information will be generated by equipment installed on

board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or

radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation

point will be established and confirmed for accuracy by the pilot.

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 fuel 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 UAS provides approximately 40 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS 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.

Meldahl believes that an exemption from 14 CFR §91.151 (a) falls within the

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin

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Corporation to operate without compliance 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. Additionally, limiting UAS flights to

10 minutes would greatly reduce the utility for which the exemption will be granted.

 

Meldahl believes that an equivalent level of safety can be achieved by limiting

flights to 30 minutes or 25% of battery power whichever happens first. This restriction

would be more than adequate to return the UAS 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, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

 

The regulation provides in pertinent part:

 (a) Except 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 person may operate a civil aircraft unless the airworthiness

 certificate required by 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 crew.

 

The UAS fully loaded weighs no more than 55 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 UAS.

 An equivalent level of safety will be achieved by keeping these documents at the

ground control point where the pilot flying the UAS will have immediate access to them;

to the extent they are applicable to the UAS. The FAA has issued numerous exemptions

to this regulation. A representative sample of other exceptions includes Exemption Nos.

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

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repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or maintain

the aircraft in compliance 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 handbook.

As the manufacturer does not provide specific maintenance instructions, maintenance

will be "on condition" for all aircraft and each aircraft will have a maintenance log.

 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 restricted 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 Manual, the

operator will ensure that the UAS is in working order prior to initiating 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. If the operator

encounters a maintenance issue which cannot be addressed, the UAS will be returned

to the manufacturer or a qualified repair facility where such repairs or maintenance can

be performed .

 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. §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);91.109; 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) to operate

commercially a small unmanned vehicle (551bs or less) in aerial photography and aerial

filming operations.

 Approval of exemptions allowing commercial operations of UASs in the aerial

photo and film industry will enhance safety by reducing risk. Conventional film

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 neighborhood of 4,0001bs.,

carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the film

location. In contrast, a UAS weighing fewer than 55 lbs. and powered by batteries

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel

carried on board. The UAS is carried to the film set and not flown . The UAS 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, including exempting the applicant from the

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requirements of Part 21 and allowing commercial operations. These lightweight aircraft

operate at slow speeds, close to the ground , and in a sterile environment and, as a

result, are far safer than conventional operations conducted with turbine helicopters

operating in close proximity to the ground and people.

Privacy

 All flights will occur over private or controlled access property with the property

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.

 If you have any questions or need any additional information, please contact the

undersigned at 425.772.3885 or pcab2004@gmail.com

Sincerely yours,

Bryan Trevor Meldahl

12303 Harbour Pointe Blvd O201, Mukilteo Wa 98275 T: 425.772.3885 E:pcab2004@gmail.com