Filmed Imagination Marius Haugan 1021 NGenesee Ave #1 Los Angeles CA 90046 marius@filmedimagination.com May

### 31, 2015
US DepartmentOfTransportation
Federal Aviation Administration
800 IndependenceAve SW Washington DC 20591

Dear Sir or Madam: z-- -· ;..

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and CFR Part 11, Filmed Imagination Inc, owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Filmed Imagination Inc may operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted within and underthe conditions outlined herein oras maybe established by the FAA as required bySection 333.
Filmed Imagination Inc is co- owned by Marius Haugan. All operations will be performed withthe public's safetyand rightto privacy safe guarded at all times.
As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation's ( the FAA Administrator's) responsibility to" establish requirements for safe operation ofsuch aircraft systems in national airspace systems." Section 333(cL ofthe Reform Act.
Filmed Imagination's UASs are rotorcraft weighing less than 55 pounds including payload. (The DJI Phantom 2 Quad Copter)They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. Both have an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area as described belowand at 200feet}\GL orless with an observer located close at hand asto make voice communication possible. These operations will not create a hazard to users ofthe nation airspace, public northe environment.Filmed Imagination Inc respectfully requests the grant ofan exception tothefollowing specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASsforcommercial use,
14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (aL 91.9 (b) (2) 91.103 (bL 

### 91.109, 91.119, 91.121,91.15UaL 91.203(a) &(bL91.405(a),91.407(a)(1L 91.409(a)&(b).

Filmed Imagination Inc submitsthis application in accordance with the Reform Act ,112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR'S operating to prevent Filmed Imagination Inc future commercial use ofsmall UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public's interest to do so. Filmed Imagination lncs UASs meet the definition of "small unmanned aircraft" as defined in Section 331 and thereforthe integration ofthese UASs
are expressly contemplated by the Reform Act. Filmed Imagination Inc would like to operate its lightweight UASs priortothe time period by which the Reform Act requires the FAAto promulgate rules governingsuch aircraft.
The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary ofTransportation is required to determine which UASs do create a hazard to users ofthe national airspace system orthe public orpose athreatto national security in lightofthefollowing:

The UASs size, speed, weight and operational capability Operation ofthe UASs in close proximityto airports and populated areas Operation ofthe UASs withinvisual lineofsight ofthe operator
Reform Act 333(a). Ifthe secretary determines that such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.

Filmed Imagination Inc are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots and have the capability to operate in the vertical and horizontal plane simultaneously. The UASs will operate only within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. These will not present ahazard tothe national airspace northe public.
The very small nature ofthese UASs combined with the safe guards presented below, will allowforthe safe operation greaterthan that envisioned by Congress forthe FAAto establish and by exemption allow commercial operations of UASs to commence immediately. Also due tothe size of UASs and the areas and altitudes they will operate approval ofthis exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk managementprocess. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act/ as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereby benefitingthe greater public's interest. Accordingly, the applicant requests thatthe FAA grantthe requested exemption withoutdelay.
The following will be considered as the binding limitation on operations of Filmed Imagination Inc,
1. Flightswill onlyoccur in the daytime hours, 2. Flights will be operated in the line ofsight oftheoperator( PIC) and Observer,(VSO) 3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by manufacturers recommendations, 4. The UASs will weigh less that55 lbs., 5. Flightswill be operated at 200 feetAGL or less. 6. Crew will be at a minimum of operator(PIC) and an observer and/or camera operator(VSO), 7. Operatorand crewwill remain in contact duringtheflight operation, 8. The UASs operator will perform a check of the flight area and make certain of the safetyofall persons in the area, 9. Consent will be obtained from all persons with in thevideo capabilities ofthe unitsto further reducethe chance ofviolating anyone's privacy. 10.All required FAA clearances, will be obtained and distances from airports strictly observed. 11.All UASs will have the capability to return automatically to the operator in a safe
mannerwiththe auto returnfunction checked and working. 12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned tooperatethe UASs atasafe distancefrom the main fishing boat. 13. Flights will onlyoperate in VFR conditions. 14. UASs have a function on the control to tell operator the distance away from the operatorand its batterypower remaining. 15. Flight team will communicate byvoice and the use oftwo-way radio ifthe area is too bigto hearvoicefrom all team members. 16. UASs will be used tovideo private outings and functions, boating,jetskiing, kayaking, fishingtrips in thegulfarea and sporting eventsfrom asafe distance. 17.When operating over or near waterthe UASs will be equipped with flotation devices
so that recovery can be made as to prevent lithium battery exposure to the water table.

14CFR part 21 Subpart H: Airworthiness Certificate 14CFR 91.7(a), 91.203(a)(1)Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined
area ofoperations for Filmed Imagination Inc UASs flights permits exception from Part 21 because they 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces oflegislation permitthe FAAto exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Filmed Imagination Inc meets or exceeds each ofthese elements
As of March 23, 2015 the FAA has stated that itwill automatically grant a "blanket" COA

forflights at or under200 AGLto any UASs operatorwith asection 333 exemption.
14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable forthe same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Filmed Imagination Inc operations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable.
14CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft
14 CFR 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 such certifications and registrations at Filmed Imagination Inc operations center.
The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Filmed Imagination Inc will only operate its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizesthe presence ofany persons not essential forthese operations. Flights will only be over private propertythat the owner has consented and all persons within this video
area also give consent forthis filming. Compared toflight operations ofconventional and traditional aircraft or rotorcraft weighingfar more than 50 lbs., operating below 500 AGL withflammablefuel UASs operations present afar smaller risktothe public.Approval ofthese 333 Exemptions allowing commercial operations ofsmall UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UASs of 

### 55 lbs. or less, battery operated and fling below 

### 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The grantingofthe use ofthese small UASs by Filmed Imagination Incwill give the people another avenue to express themselves and to have avideo record to share with family and friendsforever. Granting Filmed Imagination Inc the above exemption will allowforthe expansion ofUAS systems into the future forthe safe conduct offree enterprise and the enjoyment ofthe
masses.
Filmed Imagination Inc respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Filmed Imagination Inc pursuanttothe Federal Aviation Act, 

### 85P.L. 726 {1958) as amended (theACT).



### 1021NGenesee Ave 

### #1
Los Angeles
CA 

### 90046