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Bennett Omensky P.O. 288 Rescue, Ca 956721 T: 530 642 9252 Ben@tjaviation.net ' 1r .·." :I -· . -·- 

### - ... ;**~::J** '· I -, March 29, 2015 U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe 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 Siror Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R Part 11, TJAviation Drones, developer and operatorof Small Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photographyforthe motion picture and television industry for scripted closed setfilming, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by Section 333.1 As described morefully below, the requested exemption would permitthe operation of small, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the film and television industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to" establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: TJAviation Drones Attn: Bennett Omensky Ph: 530 642 9252 Email: Ben@tjaviation.net Address: P.O. Box 288, Rescue, Ca 95672-0288

1

The conditions proposed by the applicant are drawn from Order8900.1 CHG 0, Volume 3, Chapter8-lssue a Certificate ofWaiverfor Motion Picture and Television Filming.

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252 ..• J j,;

March 29, 2015 Page Two 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) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directsthe Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determinewhich types of UASs do not create a hazard to users ofthe NAS orthe public or pose a threatto national security in light ofthe following:
0 The UAS's size, weight, speed, and operational capability; 0 Operation ofthe UAS in close proximity to airports and populated areas; and 

## o Operation ofthe UASwithin visual line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system."

### /d. §333(c) (emphasis added)2.
The Federal Aviation Act expressly grantsthe FAAthe authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes sUASs, from the requirementthat all civil aircraft must have a current airworthiness certificate.

2

Applicant interpretsthis provision to placethe duty on theAdministratorto not only process applications for exemptions undersection 333, but forthe Administrator**t~**_craft conditions forthe safe operation ofthe UAS, ifit should be determined thatthe cond1t1ons setforth herein do notfulfill the statutory requirements for approval.

P.O. Box288, Rescue, CA95672-0288 (530) 642 9252

### ·•

March 29, 2015 Page Three \ The Administrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section orany sections 44702-44716 ofthis title ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701

### (f) See also49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).
TJAviation Drone's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. Theywill operate only in line ofsight and will operate only within the sterile area as described in the Operations Manual as received bythe Motion Picture Association ofAmerica, attached as Exhibit 1(hereinafter "the Manual")3. Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public."4 Given the small size ofthe sUASs involved and the restricted sterile environmentwithin which they will operate, the applicantfalls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UASsto commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the cleardirection in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAAgrant the requested exemption without delay. AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe exemption requested herein apply to civil aircraftthat have the characteristics and that operatewith the limitations listed herein. These limitations provide for at least an equivalent oreven higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe movie and television filming operations conducted with conventional aircraft. These limitations and conditions to which TJAviation Drones agrees to be bound when conducting commercial operations under an FAA issued exemption include: 3

The Motion Picture Association ofAmerica has received this manual and has found itto be acceptable for sUAS filming operationsforthe television and movie industry. Applicant submitsthis manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary information thatthe applicant has not and will not share with others. The manual contains operating conditions and proceduresthatare not available to the public and are**p~otected** from release underthe Freedom of Information Act 5 USC 552 et.seq. 4Reform Act Section 333 (b). P.O. Box 288, Rescue, CA95672-0288 (530) 642 9252

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March 29, 2015 Page Four
1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/orobserver. 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 priorto the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than 200feet above an elevated platform from which filming is planned. 5. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator. 6. sUAS pilotwill be an FAA licensed airman with at least a private pilot's certificate and third class medical. The observerwill hold at least athird class medical. 7. sUAS Pilotwill be Pilot in Command (PIC). Ifa pilot certificate holderotherthan the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. Section 4 and 10 ofthe Manual requires the establishment ofa "Security Perimeter" forthe flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations priorto each day's production activities. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe Security Perimeter be presentforthis briefing. 10. The operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. 11. The operatorwill obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100feet oftheflight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required by Section 4 and 10 ofthe Manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. 12. The operatorwill submit awritten Plan ofActivities (Form 7711-1 or2) to the FSDO three days before the proposed shoot as required in Section 4 ofthe Manual. 13. Pilot and observerwill have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required in Section 4 ofthe Manual. 14. Observerand pilotwill at all times be able to communicate byvoice and/ortext. 15. Written and/ororal permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orother appropriate governmental agencies. 17. Ifthe sUAS loses communications orloses its GPS signal, the UASwill have capability to return to a pre-determined location within the Security Perimeter and land. 18. The sUAS will have the capability to abort aflight in case of unpredicted obstacles or emergencies.

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252March 29, 2015 Page Five 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart 

### H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, 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 neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is nowdonewith conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greaterdegree ofsafety 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 ofthese same criteria demonstratesthatthere is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display on that aircraft neareach entrance to the cabin, cockpit, orpilot 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. 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

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252March 29, 2015 Page Six "Experimental" can be placed. Giventhe size ofthe sUAV, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level ofsafetywill be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe 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 pilotsto non-commercial operations. Becausethe UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraftto have a private pilot's license ratherthan a commercial pilot's license to operatethis 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 ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level ofsafety 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 ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the present level ofsafety 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 forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists priorto each flight, as setforth in the comprehensive Manual checklists, plus Sections 3,4,8 and 10 an equivalent level ofsafetywill be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unlessthere is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof

P.O. Box 288, Rescue, CA95672-0288 (530) 642 9252March 29, 2015 Page Seven
The sUAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only becausethere is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafetywill be maintained by keeping theflight manual at the ground control pointwhere the pilot flying the sUAS 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 offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafetywill be provided as set forth in the comprehensive Manual checklists plus Sections 3,4,8 and 10 ofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.
14 C.F.R. §91.109: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft hasfully functioning dual controls. sUASs and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraft via radio communications. The FAA has approved exemptionsforflight training without fully functional dual controls for a numberofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at lessthan the minimums prescribed, provided the person operating the helicoptercomplies with any route oraltitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes upto 400AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, exceptforthe limited conditions stated in the Manual, the UAS will neveroperate at higherthan 400 AGL. Itwill however be operated in a restricted areawith security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent.

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252March 29, 2015 Page Eight The equivalent level of safetywill be achieved given the size, weight, speed ofthe UAS as well as the locationwhere it is operated. No flight will be taken withoutthe permission ofthe property owneror local officials. Because ofthe advance notice to the property ownerand participants in the filming activity, all affected individuals will be aware ofthe planned flight operations as set forth in Section 4 and 10 ofthe Manual. Compared toflight operations with aircraft or rotorcraft weighing 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 aircraftoperating ator below 500 AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these smaiiUAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "to the elevation ofthe departure airport oran appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved by the operator, pursuantto the Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 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 afterthatfor at least 30 minutes; or (2) At night, tofly afterthatfor at least45 minutes." The battery powering the sUAS provides approximately 40 minutes of powered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS 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 longertime frame for flight in daylight or nightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151(a) was intendedto alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utilityforwhich the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbattery powerwhichever happens first. This restriction would be more P.O. Box 288, Rescue, CA95672-0288 (530) 642 9252March 29, 2015 Page Nine than adequate to return the sUAS 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 haswithin 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) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance sothat it is legible to passengers orcrew. The UAS fully loaded weighs no morethan 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS. An equivalent level of safetywill be achieved by keeping these documents at the ground control point where the pilotflying the sUAS will have immediate access to them, to the extent they 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 These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part43. Given thatthese section and Part 43 apply only to aircraftwith 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 referenced in the Manual (See section 8). An equivalent level ofsafety 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 oftime. Ifmechanical issues arisethe UAS can land immediately and will be operating from no higherthan 400feet AGL. As provided in the Manual (Section 8), the operatorwill ensure that the UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the
P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252,.
March 29, 2015 Page Ten
person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.

*********
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 motion picture and television operations. Approval ofexemptions allowing commercial operations ofsUASs in thefilm industrywill enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudesjustfeet from the subject being filmed and in extreme proximityto people and structures; and presentthe risks associated with vehicles thatweigh in the neighborhood of4,0001bs., carrying large amounts ofjetA or otherfuel (140 gallonsforjet helicopters shown below). Such aircraft mustfly to and from the film location. In contrast, a sUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the film set and notflown. The sUAS will carry no passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraftflights. The operation ofsmall UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the 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 saferthan conventional operations conducted with turbine helicopters operating in close proximityto the ground and people.Privacy
All flightswill occurover private or controlled access propertywith the property owner's prior consent and knowledge. Filming will be of people who have also consented to being filmed orotherwise have agreed to be in the area where filming will take place. Set forth below are pictures ofaerial filming conducted, as flown today in highly populated and/or urban areas, with turbine powered helicopters. The grant ofthis exemption requestwill provide improved safety in both day and night operations.

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252March 29, 2015 Page Eleven

P.O. Box288, Rescue, CA 95672-0288 (530) 6429252March 29, 2015 Page Twelve

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March 29, 2015 Page Thirteen P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252



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March 29, 2015 Page Fourteen

Night operations will also be conducted by sUASs and such operations are fully lighted so that visibility is as though filming was conducted during daylight hours.

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252March 29, 2015 Page Fifteen

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS in the motion picture and television industry pursuantto the Manual appended hereto.

cc: James Williams

P.O. Box 288, Rescue, CA 95672-0288 (530) 642 9252