United States D~partment ofTransportation 

Docket Operatiop.s ._ ; 

1200 New Jersey Ave.SE 

West Building Ground Floor Room Wl2-140 

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 of2012 (the "Reform Act") 

and the procedures contained in 14 C.F.R 11, to request that Moments Relived Photography LLC, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations 

(FAR's) listed below so that Moments Relived Photography, may operate its small unmanned 

aircraft/lightweight unmanned aircraft systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA); as long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

As identified and described herein, Anthony Vining, and his company Moments Relived 

Photography LLC, is an experienced, licensed, and insured company. 

Anthony Vining has a full and unique understanding of the safety precautions, and laws that must be 

observed and adhered to, that's why we seek to have this approvaL 

Moments Relived Photography LLC has been actively involved in the technical development 

of UAS/UA V service applications to provide high definition film quality by aerial cinematography 

with small, unmanned aircraft and lightweight UASs. It is currently one of the very few companies that 

is developing advanced technical applications and abilities for future commercial service applications. 

Moments Relived Photography LLC has fully equipped each of its small unmanned aircraft for aerial 

photography and cinematography. Through given their stability and maneuverability, they may be 

used for other cinematography, by law enforcement personnel, search and rescue and by other first 

responders. 

Moments Relived Photography LLC has rejected all offers to work with film, television, 

commercial television production companies on locations within the United States to ensure it is in 

compliance with any applicable FARs. It, like other applicants, has done so despite Judge Patrick G. 

1 
Geraghty's decision in the Rapheal Pirker matter and his reasoning that no F ARs prohibits the use of 

small unmanned aircraft or lightweight UASs like those flown by other peer companies. 

Moments Relived Photography LLC exemption request would permit its operation of 

lightweight, unmanned (remotely controlled in line of sight) UASs in tightly controlled and limited 

airspace. Predetermined, specifically marked areas of operation cordoned off locations and 

corresponding enhancements to current safety controls will allow Moments Relived Photography LLC 

to operate within current safety parameters and new ones being implemented. As identified, similar 

lightweight, remote controlled UASs are legally operated by amateurs who refuse to seek approval 

before use of such devices, safety plan or controls in place to prevent catastrophe. Moments Relived 

Photography LLC is developing a state-of-the art client website application to monitor, evaluate and 

implement all aerial cinematography activities with a pre-flight safety and flight plan system. 

Granting Moments Relived Photography LLC request comports with the Secretary of 

Transportation's (FAA Administrator's) responsibilities to not only integrate UASs into the national 

airspace system, but to " ... establish requirements for the safe operation of such aircraft systems 

(UASs) in the national airspace system" under Section 333© of the Reform Act. Further, Moments 

Relived Photography LLC will conduct its operations in compliance with the protocols described 

herein or as otherwise established by the FAA. 

Moments Relived Photography LLC respectfully requests the grant of an exemption allowing it 

to operate lightweight, remote controlled UAS's. 

The Specific Sections of Title 14 ofFederal Regulations, Moments Relived Photography LLC requests 

exemption are: 

14 CFR 21; 14 C.P.R. 45.23(b); 14 CFR 61.113(a) & (b); 14 C.P.R. 91, et seq; 14 CFR 407 (a)(I); 14 

CFR409 (a)(2);and, 14CFR417 (a)&(b). 

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.P.R. 45.23(b); 14 CFR Part 21;14 CFR 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) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) 

(2);91.417 (a) & (b). 

The Extent of Relief Moments Relived Photography Services Seeks and the Reason it seeks Such 

Relief: 

Moments Relived Photography LLC submits this application in accordance with the Reform 

Act, 112 P.L. 95 ss 331-334, seeking relief from any currently applicable PARs operating to prevent 

Moments Relived Photography LLC contemplated commercial cinematic, research and other flight 

operations within the national airspace system. There Reform Act in Section 332 provides for such 

integration of civil unmanned aircraft systems into our national airspace systems into our national 

airspace system as it is in the public's interest to do so. Moments Relived Photography LLC 

lightweight UASs meet the definition of "small unmanned aircraft: as deemed in Section 331 and 

therefore the integration of Network Media Services lightweight UASs are expressly contemplated by 

the Reform Act, Network Media Services would like to operate its lightweight UASs prior to the time 

period by which the Reform Act requires the FAA to promulgate rules governing such craft. 

2 
The Reform Act guides the Secretary in determining the types ofUASs 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 s 333 (a). Each of these items militates in favor or an exemption for Network Media 

Services. 

Moments Relived Photography LLC UASs utilizes three to four counter-rotating propellers for 

extreme balance, control and stability. They each weigh less than 30 pounds, including cinematic or 

other equipment. Each of Moments Relived Photography LLC small unmanned aircraft are designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of 

vertical and horizontal operations but operate only within the line of sight of the remote control pilot. In 

addition to the remote control pilot, Moments Relived Photography LLC uses a spotter and a technician, 

such that, at minimum, two Moments Relived Photography LLCs personnel govern the safe flight of an 

Moments Relived Photography LLC aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and 

twenty minutes. Moments Relived Photography LLC does not operate its UASs with less than twenty 

five percent battery capacity. Safety systems in place include a GPS mode that allows Moments 

Relived Photography LLC UASs to hover in place if communication with the radio control pilot is lost 

and then slowly descend the UAS at twenty five percent battery capacity. Further, Moments Relived 

Photography LLC fleet is programmed, in some instances, to slowly follow a predetermined set of 

waypoints to return to a safety point if communications are lost. 

Moments Relived Photography LLC does not operate its UASs near airports and generally does 

not operate them near populated areas. The UAS operating software and GPS navigation systems do not 

allow any of the Moments Relived Photography LLC UAS vehicles to operate near airports or restricted 

fly zones. The failsafe software will disable the UAS vehicles from taking off and also limit the fly 

zones. The failsafe software will disable the UAS vehicles from taking off and also limit the UAS 

systems from operating within specific GPS present no-fly zones. To date, Moments Relived 

Photography LLC has only operated its fleet on private property cordoned off areas under the control 

ofMoments Relived Photography LLC clients. Moments Relived Photography LLC onlyoperates its 

UASs in predetermined areas and only in compliance with well-regarded safetyprotocols. 

Moments Relived Photography LLC operation of its fleet of small unmanned aircraft will not 

"create a hazard to users ofthe national airspace system or the public." 112 P.L. 95 s 333 (b). Given 

the small size andweight of Moments Relived Photography LLC UASs, combined with their operation 

in cordoned off and well-controlled areas, Moments Relived Photography LLC fleet 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, Moments Relived Photography 

LLC UASs have a demonstrable safety record and do not pose any threat to the general public or 

national security. 

3 
The FAA has the authority to issue the exemption to Moments Relived Photography LLC 

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

Public Benefits. 

Granting Moments Relived Photography LLC exemption request furthers the public interest. 

First, 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 ofthe Reform Act. Second, Moments 

Relived Photography LLC conducts research into safe UAS operations every time it flies one of its 

UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to further 

enhance current safety protocols. Allowing Moments Relived Photography LLC to log more flight 

time directly relates to its research and its ability to further enhance current safety measures. Third, the 

public has an interest in reducing the danger and emission associated with current aerial capture 

methods, namely, full size helicopters. Moments Relived Photography LLC UASs are battery powered 

and create no emissions. If a Moments Relived Photography LLC lightweight UASs is far less than a 

full size helicopter, notwithstanding the statistically noteworthy safety record of full size 

helicopters. Moments Relived Photography LLC UASs are battery powered and create no emissions. If a 

Moments Relived Photography LLC crashes there is no fuel to ignite and explode. The impact of 

Moments Relived Photography LLC lightweight UASs is far less than a full size helicopter, 

notwithstanding the statistically noteworthy safety record of full size helicopters used in aerial 

photography. The public's interest is furthered by minimizing ecological and crash impacts by permitting 

aerial photography through Moments Relived Photography LLC lightweight UASs. 

Progression of the arts and sciences has been fundamental to our society since its inclusion in 

the United States Constitution. Indeed, Congress mandates the integration ofUASs into our national 

airspace system, in part, to achieve progression in the noteworthy, and inevitable, field. Permitting 

Moments Relived Photography LLC to immediately fly within the United States furthers these goals. 

Whether it is the amalgam of scientific discoveries applicable to feature film making (including those 

drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in 

publicly usable technologies or advancements in equipment available to law enforcement 

personnel/first responders that does not cost millions of dollars, granting Moments Relived 

Photography LLC exemption request substantially furthers the public's interest in ways known and 

currently unknown. 

4 
Reasons Why Moments Relived Photography LLC Exemption Will Not Adversely Affect Safety or 

How the Exemption Will Provide a Level of Safety at Least Equal to Existing Rule: 

Moments Relived Photography LLC exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated, supra, permitting Moments Relived Photography LLC to log more flight 

time in FAA controlled airspace will allow Moments Relived Photography LLC to innovate and 

implement new and as of yet undiscovered safety protocols. In addition, Moments Relived Photography 

LLC submits the following representations of enhancements to current aerial picture capture techniques: 

• Moments Relived Photography LLC UASs weigh less than 30 pounds complete with 

digital cameras 

• Moments Relived Photography LLC only operates its UASs below 400 feet; 

• Moments Relived Photography LLC UASs only operate for 5-25 minutes per flight; 

• Moments Relived Photography LLC lands its UASs when they reach 25% battery power; 

• Moments Relived Photography LLC remote control pilots operate Moments Relived 

Photography LLC UASs by line of sight; 

• Moments Relived Photography LLC remote control pilots have video backup should 

they somehow lose sight of the UAS; 

• Moments Relived Photography LLC staffs each flight with a remote control pilot 

technician and spotter with communication systems enabling real time 

communication between them; 

• Moments Relived Photography LLC UASs have GPS flight modes whereby they 

hover and then slowly land if communication with the remote control pilot is lost or 

battery power is below 25% 

• Moments Relived Photography LLC actively analyses electronic flight data 

and other sources of information to constantly update and enhance safety 

protocols; 

• Moments Relived Photography LLC only operates in secured areas that are strictly 

controlled, are away from airports and populated areas; 

• Moments Relived Photography LLC conducts extensive briefings prior to flight, 

during which safety carries primary importance; 

• Moments Relived Photography LLC always obtains all necessary permission and 

permits prior to operation; and, Moments Relived Photography has procedures in 

place to abort flights in the event of safety breaches or potential danger. 

5 
Moments Relived Photography LLC provides a level of safety at least equal to existing rules, 

and in nearly every instance, greater than existing rules. It is important to note that absent the integration 

of commercial UASs into our national airspace system, helicopters are the primary means of aerial 

photography. 

While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery 

powered lightweight USAS. First, the potential loss of life is diminished because UASs carry no 

people of board and Moments Relived Photography LLCs only operates them in specific areas away 

from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for fire explosions is greatly diminished. 

Third, the small size and extreme maneuverability of Moments Relived Photography LLCs UASs allow 

our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when close 

enough to capture amazing images, Moments Relived Photography LLC UASs need not be so close to 

the objects they are focused on. 

Accordingly, Moments Relived Photography LLC UASs have operated and will continue to operate at 

an above current safety levels. 

A summary The FAA May Publish in the Federal Register: 

A. 14 C.P.R. 21 and 14 C.P.R. 91; Airworthiness Certificates, Manuals and The like. 

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

procurement of necessary airworthiness certificates in relation to FAR s 91.203(a){l). The size, 

weight and enclosed operational area of Moments Relived Photography LLC UASs permits 

exemption from Part 21 because Moments Relived Photography LLC UASs meet an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. s 44701 

(f)) and Section 333 ofthe Reform Act. 

Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate 

requirement in consideration of the right, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Moments Relived Photography LLC UASs meet to 

exceed each ofthe elements. 

14 C.P.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 F ARs, this Regulation is 

inapplicable. 

6 
14 C.F.R. s 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 issues exemptions to the regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 3 2 8 2 7. 

B. 14 C.F.R. s 45.23: Marking of The Aircraft 

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

specifications. Moments Relived Photography LLC UASs are, by defamation, unmanned. They 

therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. 

Further, two-inch lettering is difficult to place on such small aircraft. Regardless, Moments Relived 

Photography LLC will mark its UASs in the largest possible lettering by placing the work 

"EXPERIMENTAL" on its fuselage as required by 14 C.F.R. s 45.29(t) so that the pilot, technician, 

spotter and others working with the UA V will see the markings. The FAA has previously issues 

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

C. 14 C.F.R s 61.113: Private Pilot Privileges and Limitations: PIC 

Pursuant to 14 C.F.R. ss 61.113(a) & (b), private pilots are limited to non-commercial operations. 

Moments Relived Photography LLC can achieve an equivalent level of safety as achieved by 

current Regulations because Moments Relived Photography LLC UASs do not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, 

though Moments Relived Photography LLC pilot vetting and training programs will. Further, 

private pilot licensees will operate Moments Relived Photography LLC UASs with the same skill. 

Further, the risks attendant to the operation of Moments Relived Photography LLC UASs is far 

less than the risk levels inherent in the commercial activities outlines in 14 C.P.R. s 61, et seq. 

Thus, allowing Moments Relived Photography LLC to operate its UASs with a private pilot as the 

pilot in control will exceed current safety levels in relation to 14 C.F.R. s 61.113(a) & (b). 

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

7 
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. Moments Relived Photography LLC UASs will never 

operate at an altitude greater than 400 AGL. Moments Relived Photography LLC will, however, operate 

its UASs in cordoned off areas with security providing a level of safety at least equivalent to those in 

relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of Moments Relived 

Photography LLC UASs, an equivalent level of safety will be achieved. 

E. 14 C.F.R 91.405 (a); 407 (a) (1);409 (a) (2);417 (a)&9b): Maintenance Inspections. 

The above-cited regulations require, amongst other things, aircraft owner and operators to have [the] 

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 par t43 of this 

chapter. 

These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to 

Moments Relived Photography LLC should its requested exemption be granted. Moments Relived 

Photography conduct an extensive maintenance program that involves regular software updates and 

constant inspection for assessment of any damaged hardware. Therefore, an equivalent level of safety will 

be achieved. Moments Relived Photography has researched and developed it's own designs. 

F. Summary 

Moments Relived Photography LLC seeks an exemption from the following regulations: 14 C.F.R. 21, 

subpart H; 14 C.F.R45.23(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; 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)(l); 14 C.F.R. §91.409(a)(2); 

14 C.F.R. §and, 14 C.F.R. §§ 91.4179(a) & (b) to commercially operate its fleet of small, light, 

unmanned aircraft for the purposes of aerial photography/video, and to conduct its own research, and 

develop platforms for first responders, search and rescue. 

Granting Moments Relived Photography LLC request for exemption will reduce current risk levels and 

thereby enhance public safety. Currently the aerial photography industry relies primarily on the use on 

full scale, large aircraft running on combustible fuel. Moments Relived Photography LLC craft do not 

contain potentially explosive fuel, are smaller, lighter, and more maneuverable than conventional aerial 

camera platforms. Further, Moments Relived Photography LLC operated at lower altitudes and in 

8 
controlled airspace. Moments Relived Photography 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 Moments Relived Photography LLC UA V's and therefore the likelihood of 

death or serious bodily injury is significantly limited. Moments Relived Photography LLC UA V's weigh 

less than 30 lbs. and travel at speeds less than 50 knots in cordoned off areas will provide at least an 

equivalent level of safety as thatachieved under current F ARs. 

Moments Relived Photography LLC Respectfully requests that the FAA grant its exemption request 

without delay. The FAA has the authority to issue the exemption sought by Moments Relived 

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

Sincerely, 

Anthony Vining 

Moments Relived Photography LLC 

P.O. Box 10 

Snellville, Ga 30039 

9