Charles R. Lawson, CPP

Quantum Imaging, Inc. (804) 436-9999 info@thehighlanderstudios.com

July 16, 2015

U. S

. D epartment o f Transportation

Docket M anagement S ystem

1 200 New J ersey A ve., SE Washington, D C 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 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).

Dear S ir or M adam:

Pursuant t o S ection 333 of the FAA M odernization and Reform A ct o f 201 2 (the Reform Act) a nd 14 C .F.R. P art 11, Quantum Imaging,Inc.

, photographer and o perator of Small

U nmanned Aircraft S ys tems (“sUASs”) e quipped to c onduct aerial phot ography for t he motion picture

, television , historic preservation, and real estate industr ies for s cript ed , highly planned

clos ed set f ilming

, hereby appl ies for a n exempti on from t he l isted Federal A viation Regulations ( “FARs”) t o al low c ommercial oper ation of i ts s UASs, so long a s such operations a r e conducted

within and under

t he conditions out lined herein or as may be established by t he FA A a s r equired by S ection 333. 1

As des cribed m or e fully bel ow, t he r equest ed exemption would permit the operation of small, un manned and r elatively i nexpensive sUAS under c ontrolled conditions in airspace t hat i s 1) limited 2) pr edetermined 3) c ontrolled as to access and 4) w ould provide safety

enhancements t o the already s afe ope rations the commercial photography industry pr esently

us ing conventional ai rcraft. Approval of t his ex empti on would thereby enhanc e s afety and fulfill

t he Secretary o f Transportation’s ( the FA A A dministrator’s) r esponsibilities t o “...establish requirements for

t he safe oper ation of s uch ai rcraft s ystems i n t he nat ional airspace system.” Section 333(c) o f the R eform A ct.

The nam e and address o f the applicant i s: Quantum Imaging, Inc.

Attn: Charles R. Lawson

Ph: 804-436-9999

Email: info@thehighlanderstudios.com

Address: 310 North Main Street, Kilmarnock, VA 22482

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8

- Issue a Certificate of Waiver for Motion Picture and Television Filming.July 16, 2015

Pag e Two

R egulations from which the exemption is requested:

14 C FR 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) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

T his 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:

• T he 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.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the nat ional airspace system.” Id. §333(c) (emphasis added) 2

.

T he 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 §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must

have a current airworthiness certificate.

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS , if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.July 16, 2015

Pag e Three

The A dministrator

m ay gr ant an exemption from a r equirement o f a r egulation prescribed

under su bsecti on (a) or ( b) o f this se ction or a ny s ections 44702

- 44716 of this t itle if t he

Administrator finds t he exemption in the publ ic i nterest. 49 U.S.C. §44701 (f) See also 49 US C §44711(a); 49 U SC §447 04; 14 C FR §91. 203 ( a) ( 1).

Quantum Imaging, Inc.'s s UASs ar e "quadcopter" rotorcraft

, w eighting 55 or f ewer l bs.

i nc luding pay load. They oper ate, under nor mal c onditions at a speed of no more t han 50 knots

and hav e the c apability t o hover, and mov e in the v ertical and horiz ontal pl ane simultaneously. They w ill operate onl y i n line of s ight and w ill oper at e only w ithin a sterile area planned and logged in UAS Pilot Log Expanded Edition: Unmanned Airc raft Systems Logbook for Drone
Pilots & Operators, 2015 from Droneprep. P r o p o s e d a i r c r a f t w i l l b e b o t h a D J I I n s p i r e a n d a D J I

P h a n t om 3 P r o f e s s i ona l

. Ai r c r a ft wi l l n e v e r b e o pe r a t e d i n s u c h a w a y a s t o t ransverse a mass

o f peo pl e

, r a t h e r mai nt a i ni ng a s a f e o p er a ti n g d i sta n c e. S u ch op er a ti o ns w ill i nsur e that t h e

s U A S w ill “ n ot c r e at e a h az a rd to u s e r s o f t h e n a t i o n a l a i r s pa c e s yst e m o r t h e g e n e ra l p u b l i c

.

Giv en the small s ize of the sUASs i nvolved and the restricted sterile environment w ithin which they w ill oper ate, t he applicant falls squarely within that z one of s afety ( an equivalent

level o f s afety) i n w hich Congress env isioned that the FAA must, by ex emption, al low

commercial oper ations o f U ASs to commence i mmediately. Also due t o the size of the UASs

and the r estricted areas i n which the relevant s UASs w ill oper ate, appr oval o f t he appl ication
presents no national s ec urity i ssue. Giv en the clear di rection in Section 333 of t he R eform A ct, the authority c ontained in the Feder al A viation Act, as amended; t he strong equivalent l evel of safety s urrounding the proposed operations, and the significant publ ic ben efit, i ncluding enhanced safety, reduction in environmental i mpacts, i ncluding reduced e missions as sociated with allowing battery-operated U ASs for filming operations

, the grant o f t he reques ted exemptions is i n the publ ic i nterest. Accordingly, t he applic ant respec tfully r e quests that t he

FAA gr ant t he requested ex emption without del ay.

AIRCRAFT AN D E QUIVALENT L EVEL OF SAF ETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe movie and television filming operations conducted with conventional aircraft

.

Thes e limitations and c onditions t o which Quantum Imaging, Inc. ag rees t o b e bound

when conduc ting c ommercial o perations unde r an FA A i ssued ex emption include:

4 Reform Act Section 333 (b).July 16, 2015

Pag e Four

1. The s UAS w ill w eigh less t han 55 lbs.

2. Flights w ill be operated within line of s ight o f a pi lot and /or obs erver. 3. Maximum t otal flight t ime f or ea ch oper ational flight w ill be 30 minutes. Flights w ill be

terminated at 25% ba ttery po wer r eserve should t hat oc cur p rior t o the 30 minute

limit.

4. Flights w ill be operated at an altitude o f no m ore than 400 feet A GL or

, not m ore t han

200 feet abov e an el evated platform from w hic h filming is pl anned.

5. Minimum crew for eac h operati on will consist of t he sUAS Pilot, t he Visual Observer,

and the C amer a Operator.

6. s UAS P ilot w ill be Pilot i n Comm and (PIC).

7. The UAS w ill onl y oper ate within a confi ned “Sterile Area” a s de fined i n the Logbook a forementioned. This will require the creation of a safe and secure operating p erimeter.

8. A br iefing w ill be conducted in regar d to the planned sUAS oper ations pr ior t o each day’s pr oduction activities. It w ill be mandatory t hat al l per sonnel w ho will be performing dut ies w ithin t he boundaries o f t he safety per imeter be present for this briefing.

9. T he operator will obtai n t he consent of all persons involv ed in t he filming and ensu re that only consenting persons will be allowed withi n 100 feet of t he flight operation,

and this r adius m ay be reduced to 30 feet bas ed upon an equivalent l evel of s afety

determination

. With the adv anced permission of t he relevant flight safety

coordinators

, o perations at c loser r ange c an be approved.

10. T he operator will submit a writt en Pl an of Activities t o t he flight safety coordinator designated by the client thr ee days before the propos ed shoot

. 11. Pilot and observer will hav e been trai ned i n operati on of UAS generally and received

up -t o -d ate information on the particular U AS t o be operated

. 12. Observer

a nd pilot w ill at al l t imes be able t o c ommunicate by v oice and/or t ext.

13. Written and/or

or al pe rmissi on from t he r elevant p roperty hol ders w ill be obtained.

14. All r equired permissions and permits w ill be obtai ned from t erritorial, s tate, c ounty or city j urisdictions, i ncluding l ocal l aw enf orcement, fire, or ot her appr opriate governmental a gencies.

15. If t he sUAS loses c ommunications o r l oses i ts G PS s ignal, the UAS w ill ha ve capability t o return to a pr e -d etermined location within the Security P erimeter and

land.

16. T he sUAS will hav e t he capability t o abort a flight i n cas e of unpredict ed obstacles or emergencies.July 16, 2015

Pag e Five

14 C.F.R. P art 2 1, S ubpart H : Airworthiness C ertificates 14 C .F.R. §9 1. 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 sUAS 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 as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, 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 operati on, 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 t he Aircraft

T he regulation requires:

W hen 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 words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

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

ne eded as the UAS will have no entrance to the cabin, cockpit or pilot station on which the wordJuly 16

, 201 5

Pag e Six

“Experimental” ca n be pl aced. Given the si ze of t he sUAV, two

- inch lettering will be impossible.

The w ord “Experimental” w ill be placed on t he fuselage i n compliance with §45.29 ( f).

The e quivalent l evel of s afety w ill be provided by hav ing t he sUAV m arked on its fuselage as r equired by §45. 29 (f) w her e the pilot, obse rver and others w orking with t he sUAV

will se e the identificati on of the UAS as “ Experimental.” The FA A has i ssued the following exemptions t o t his r egulation to E xemptions N os. 10700, 8738

, 10167 and 10167A.

14 C.F.R. § 61. 113 ( a) & ( b): P rivate Pilot P rivileges and Limitations: P ilot i n C ommand.

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 sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and a ll flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual 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 sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS 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): C ivil ai rcraft a irworthiness.

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 Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) ( 2): C ivil Aircraft Flight M anual i n t he Aircraft.

S ection 91.9 (b) (2) provides:

N o person may operate a U.S.

- registered civil aircraft ...

( 2) For which an Airplane or Rotorcraft Flight Manual is not required by §21. 5

o f this chapter, unless there is available in the aircraft a current approv ed

ai rplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.July 16, 2015

P ag e Seven

The sU AS, giv en its si z e and configuration has no abi lity or pl ace to carry s uch a flight

manual on the ai rcraft, n ot onl y beca use there i s no pilot on board, bu t be cause there is no

room o r ca pacity t o ca rry su ch an i tem on t he ai rcraft.

The e quivalent l evel of s afety w i ll be maintained by k eeping t he flight manual at the ground control poi nt w her e the pilot flying the sUAS w ill hav e immediate access to it. The FAA

has issued the followin g ex emptions t o t his r egulation: E xemption N os. 86 07, 8737

, 8738

, 9299

, 9299A, 9565

, 9565B

, 10 167, 10167A

, 10602

, 32 827, and 10700.

14 C.F.R. § 91. 103: P reflight ac tion

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. An equivalent level of safety will be provided as set forth in Sections J and K of the Manual. 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 .109: Fl ight i nstruction :

Section 91.103 pr ovides that no perso n may oper ate a ci vil ai rcraft ( except a manned

free bal loon) t hat i s bei ng use d for flight i nstruction unless that ai rcraft has fully functioning dual

controls.

s UASs and remotely pi loted aircraft, by t heir desi gn do not hav e fully functional dual

controls. Flight co ntrol i s acco mplished throug h the use of a co ntrol box that co mmunicates w ith

the aircraft v ia radi o communications. The FA A h as appr oved exemptions for f light t raining

without fully f unc tional d ual co ntrols for a num ber

o f ai rcraft and for

f light i nstruction in experimental ai rcraft. S ee Exemption Nos.5778K & 9862A

. The equivalent level of sa fety provided by t he fact that neither a pi lot no r

pas sengers w ill be carried i n the aircraft and by the size and speed of t he ai rcraft.

14 C.F.R. §91 .119: Minimum saf e al titudes

Section 91.119 es tablishes sa fe al titudes for oper ation of ci vil ai rcraft. Section 91.119 (d) allows hel icopters t o be operated at l ess t han t he minimums pr escribed, p rovided the person operating the helicopter co mplies w ith any r out e or al titudes p rescribed for hel icopters by t he

FAA. As t his ex em pti on is for a sUAS t hat i s a helicopter and t he ex emption requests a uthority
to operate at al titudes up t o 400 AGL, or not more t han 200 abov e an el evated platform f rom which filming is p lann ed, an exempti on may be needed to al low su ch operations. As set forth herein, ex cept for

t he limited conditions stated i n the Manual, t he UAS w ill never oper ate at higher t han 400 AGL. It will ho wever be operated i n a restricted ar ea w ith security per ime ter, where buildings and people will not be expose d to operations w ithout their pr e

- obtained

consent.July 16, 2015

Pag e Eight

The e quivalent l evel of s afety w ill be achieved given the si ze, w eight, sp eed of t he U AS

as w ell as t he location w here it i s ope rated. N o flight w ill be taken without the permission of the
property ow ner

or l ocal o fficials. Because o f t he a dvance notice to t he pr operty ow ner and participants i n the filming activity, al l a ffected i ndividuals w ill be aware of t he pl anned flight operations a s se t forth in Section K o f t he M anual. Compar ed t o flight ope rations with aircraft o r rotorcraft w eighti ng far

m or e t han t he maximum 5 5lbs. pr oposed herein and the l ack o f

flammable fuel, any r isk associated with these operations i s far l ess t han t hose presently

prese nted w it h conventional ai rcraft oper ating at o r bel ow 500 AGL i n the movie industry. In addition, t he l ow

- altit ude operations o f the sU AS will ensu re separation between these small

UAS oper ations an d t he operations o f conventional ai rcraft t hat must co mp ly with Section

91.119.

14 C.F.R. §91

. 121 Altimeter S ettings

This regulati on requires each person oper ating a n aircraft t o maintain cruising al titude by

reference to an al timeter that i s se t “...t o the elevation of t he depar ture ai rport o r a n appropriate

altimeter se tting av ailable before departure.” As the sUAS m ay no t have a bar ometric al timeter,

but i nstead a G PS altitude read out

, an ex emption m ay be needed. An e quivalent l evel of safety w ill be achieved by t he operator, pu rsuant t o the Manual and Sa fety Ch eck list

, confirming the al titude o f t he l aunch site sh own on the G PS al titude indicator be for e flight.

14 C.F.R. § 91. 151(a): Fuel R equirement s for Flight i n VFR Conditions

Section 91.151 ( a) p rohibits an individual f rom be ginning “a flight i n an ai rplane under

VFR co nditions unl ess (considering wind and forecast w eather co nditions) there i s enou gh fuel

t o fly t o t he first poi nt o f i ntended landing, and, as suming normal c ruising speed – (1) D uring t he day, t o fly a fter

t hat for a t l east 30 minute s; or ( 2) A t night, t o fly after t hat f or at least 45

minutes.”

The bat tery pow ering the sU AS pr ovides approximately 40 minutes o f po wered flight. To

meet t he 30 minute r eserve requirement i n 14 C FR §91. 151, sU AS flights would be limit ed to approximate ly 10 minutes i n length. Given the l imitations on the UAS’s p ropose d flight area and

the location o f i ts pr oposed operations w ithin a predetermined area, a longer t im e frame for flight i n daylight or

ni ght VFR co nditions i s reasonable.

Applicant bel ieves that a n exempti on from 14 C FR §91. 151(a) f alls w ithin the scope o f prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporati on to operate

without co mpliance with FAR 91. 151 (a)). Operating the small U AS, i n a tightly co ntrolled area

wher e only peopl e and property ow ners or official r epresentatives w ho have signed w aivers w ill be allowed, w ith less t han 30 minutes o f r eserv e fuel, does no t en gender t he type of risks that Section 91.151(a) w as i nt ended to alleviate giv en the size and speed of the sm all UAS. Additionally, l imiting sUAS flights to 10 minutes w ould greatly r educe t he u tility f or w hich the exemption will be granted.

Applicant bel ieves t hat a n equivalent l evel of sa fety ca n be ach ieved by l imiti ng flights to

30 minutes o r

25 % o f ba ttery pow er

w hichever

happens first. This r estriction would be moreJuly 16, 2015

Pag e Nine

than adequat e t o retur n the sUAS t o i ts pl anned landing z one from any where in its l imited operating a rea.

Similar ex emptions hav e been granted t o ot her operations, i ncluding Exemptions 2689F,
5745, 10673

, and 10808.

14 C.F.R. §91

. 203 (a) an d (b): Carrying Civil Aircraft C ertification and Registration

T he 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) A n 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 i ss ued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible t o

pas sengers or crew.

T he 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 sUAS.

A n equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent

the y are applicable to the sUAS. 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

T hese regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

G iven that these section and Part 43 apply only to aircraft with an airw orthiness 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 referenced in the Manual.(See Sections L and Q) 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 mostJuly 16, 2015

Pag e Ten

fam iliar w ith the ai rcraft a nd best su ited t o m aintain the ai rcraft i n an ai rworthy co ndition to provide the equivalent l evel of safety.

*********

Pursuant t o 14 C.F.R. P art 11, t he following su mmary i s provi ded for publ ication in the

Federal Register, sh o uld it be det ermined t hat pu blication is needed:

Applic ant 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 (55lbs or less) in motion picture and television operations.

Approval of ex emptions allowing c ommercial ope rations of s UASs in t he f ilm industry will enhance safety by r educing risk. Conventional film ing ope rations, us ing jet o r pi ston pow er ai rcraft, operate at ex tremely l ow al titudes j ust feet from t he subject bei ng filmed a nd in extreme proxi mity t o people and s tructures; and pr esent t he risks asso ciated w ith vehicles t hat w eig h in the neighborhood o f 4 ,000lbs., carrying l arge am ounts o f jet A o r o ther fuel ( 140 gallons for j et

heli copters sh ow n below). Such ai rcraft must fly t o and from t he film l ocation. In co ntras t, a
sUAS w eighing fewer

t han 55 lbs. and pow ered by bat teries el iminates v irtually al l of t hat risk given t he reduced m ass and lack of co mbustibl e f uel ca rried on board. The sUAS i s ca rri ed to

t he film se t and not flown. The sUAS w ill ca rry no passengers o r c rew and, therefore, w ill not expose them t o t he r isks associated with manned aircraft flights.

The oper ation of s mall U ASs, w eighting l ess t han 55 lbs., conducted in the st rict

conditions out lined above, w ill pr ovide an equivalent l evel o f sa fety su pporti ng the g rant of t he exemptions r equested h erein, i ncluding exempting the appl icant from t he requirements o f P art 21 and allowing co mmercial oper ations. These lightweight ai rcraft op erate at sl ow sp eeds,

close to t he ground, and in a sterile environment and, as a result, a r e far s afer t han co nventional operations conducted w it h t urbine helicopters ope rating i n cl ose proximity t o the ground and people.

Priv acy

All f lights w ill occu r

ov er p rivate or

co ntrolled access property w ith the pr operty

owner’s pr ior

co nsent an d knowledge. Filming will be of peopl e who have also consented t o being filmed or

o therwis e have agr eed to be in the ar ea w her e filming w ill t ake pl ace.Charles R. Lawson Certified Professional Photographer President, Quantum Imaging, Inc. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in the motion picture and television industry pursuant to the Manual appended hereto.