September4, 2015
Attn: U. S. DepartmentofTransportation Docket Operations WestBuilding GroundFloor, Roomw12-140 1200NewJerseyAve, SEWashington, DC 20590

RE: OverheadFilms, LLC. REQUEST AN EXEMPTIONFROMTHEREQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERALREGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJIInspire 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAAMODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Michael Mitchell Owner/Founder OverheadFilms, LLC.

15409 ArabianWay Montverde, FL 34756 352-638-4668 mike@overhead-films.comTABLE OF CONTENTS Page GLOSSARY OFABBREVIATIONS

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SUMMARY

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INTRODUCTIONAND INTERESTS OF PETITIONER.

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BACKGROUND

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BASIS FORPETITION

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NAME AND ADDRESS OF PETITIONER

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THE SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICH OVERHEADFILMS, LLC. SEEKS EXEMPTION

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THEEXTENT OF RELIEF OVERHEAD FILMS, LLC. SEEKS AND THEREASON OVERHEAD FILMS, LLC. SEEKS THE RELIEF

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THE REASONS WHY GRANTING OVERHEAD FILMS, LLC.'S REQUESTWOULD BE IN THEPUBLIC INTEREST

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THEREASONS WHY GRANTINGTHEEXEMPTION TO OVERHEAD FILMS, LLC. WOULD NOTADVERSELYAFFECT SAFETY.

.............................................................14 SUMMARY THAT CAN BEPUBLISHED IN THEFEDERALREGISTER.

..................25 ANYADDITIONALINFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORT OVERHEAD FILMS, LLC. REQUEST

..................................................25 CONCLUSION

.....................................................................................................................25 APPENDICES

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2AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above GroundLevel AreaofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederalRegulations Certificate ofAuthorization Federal AviationAdministration FederalAviation Regulation GroundControl Station GlobalPositioning System Loss ofLink NationalAirspace System Noticeto Airman PilotIn Command FAAModernization andReformAct of2012 (FMRA) Safety Observer StandardOperatingProcedures UnmannedAircraft UnmannedAircraft System VisualFlightRules Visual Line ofSite Visual Meteorological Conditions Vertical TakeoffandLanding

3SUMMARY Overhead Films, LLC. hereafter referred to as Overhead Films seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Inspire 1) pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA). This exemption will permit OverheadFilms to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States. INTRODUCTION AND INTERESTS OF THE PETITIONER Michael Mitchell, Owner and Founder ofOverhead Films has for over 17 years ofexpertise and knowledge in video and multimedia production, advertising, public relations and training using advanced technologies and solutions. Mr. Mitchell has worked on hundreds ofproductions over the past 17+ years in all types of locations with a perfect client and employee safety record Along with Decades ofModel 

### RIC operating experience. The objective ofOverhead Films and
our Unmanned Aircraft System (DJI Inspire 1) aerial operations is to provide a more affordable, high-quality production system for a variety of governmental, commercial, public, and residentialuses, specificallytargeting

Construction sitesbefore andafter
• Appraisals
• Real-estate marketing Economic development
• Civic landmarks Special event coverage Private and governmental training
My staffhas safely flown small RC electric quadcopters recreationally for approximately 2years without incident. BACKGROUND UnmannedAircraft Systems: DJIInspire 1, UAS Overhead Films seeks an exemption to operate DJI Inspire 1 system for compensation or hire within the NAS. The DJI Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA). The DJI Inspire 1has a maximum gross weight ofapproximately 6.47 lb. while having a diagonal dimension ofapproximately 17.8", a maximum speedofapproximately 22mps and will be operated at a maximum flying height of400'. The DJI Inspire 1 is equipped with four main rotors; drivenbyLithiumPolymerbatterypoweredelectricmotors. With a flight time of 15 mins while remaining 25% ofbattery life.

4The DJI Inspire 1 that will be operatedby OverheadFilms will be registered in accordance with 49 U.S.C. 44103,Registration of Aircraft, as well as 14 C.F.RPart 47,AircraftRegistration, and markedin accordance with 14 C.P.R. Part45,Identification andRegistrationMarking.

BASIS FORPETITION Petitioner, Overhead Films, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.P.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rulesfor Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1, UAS inthe National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area associated with the umnanned aircraft and its operation, Overhead Films operation ofDJI Inspire 1 UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part21, SubpartH. Accordingly, OverheadFilms requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only applyto aircraft with an airworthiness certificate. OverheadFilms submits that the requestedreliefis proper since an equivalent level ofsafetywill be ensured. Overhead Films will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Overhead Films will document and maintain all maintenancerecords for the DJI Inspire 1UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Privatepilotprivileges and limitations: Pilot in command, is requested by Overhead Films to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Overhed Films seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. As such, OverheadFilms submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 InstructionManual), andthat the aircraft are in a condition for safe flight.

5Overhead Films also seeks an exemption from the requirements of Section 91.121, entitled AltimeterSettings, as the DJIInspire 1UAS will nothave atypicalbarometric altimeter onboard. However, altitude information ofthe DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Overhead Film's operation ofthe DJI Inspire 1 UAS within visual line ofsight, at orbelow400 feet AGL, will ensure a level ofsafety equivalentto Section 91.121.
Additionally, Overhead Films seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirementsforflight in VFR conditions. Overhead Films submits that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 22 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safelybackto pointoftake off. In accordance with 14 C.P.R. § 11.81, Overhead Films provides the following information in support ofits petition for exemption:

A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner andpoint ofcontact is: Michael Mitchell Owner/Founder OverheadFilms, LLC. 15409 Arabian Way Montverde, FL 34756 352-638-4668 mike@sixmitchells.com

6B. The Specific Sections Of 14 C.F.R. From Which Ocerhead Films Seeks Exemption.

1. Overhead Films Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, inrelevantpart: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers or property for compensation or hire;
normaythatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connectionwith anybusiness or employment if- (1) The flight is onlyincidentalto thatbusiness oremployment; and (2) The aircraft does not carrypassengers orproperty for compensation orhire. 2. Overhead Films Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraftairworthiness, subsection (a), states the following: (a) No personmayoperate a civil aircraftunless it is in an airworthycondition. 3. Overhead Films Seeks Exemption From The Requirements Of Section 91.121.Section 91.121, entitledAltimeter settings, subsection (a), states the following, inpart: (a) Eachperson operating an aircraft shall maintainthe cruising altitude orflight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nauticalmiles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or

(iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

74. Overhead Films Seeks Exemption From The Requirements Of Section 91.15l(b). Section 91.151, entitledFuelrequirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enoughfuel tofly to the firstpoint ofintended landing and, assuming normal cruising speed, tofly after that for atleast20minutes. 5. Overhead Films Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitledMaintenance required, subsection (a), states the following: Each
owner oroperator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribedinpart43 ofthis chapter[.] 6. Overhead Films seeks Exemption From The Requirements Of Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- (1) Ithas been approved for return to service by a person authorizedunder§ 43.7 ofthis chapter[.] 7. OverheadFilms seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraftunless, withinthepreceding 12 calendarmonths, ithas had-- (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service bya person authorizedby§ 43.7 ofthis chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance withpart 21 ofthis chapter.

88. Overhead Films seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled 

### Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) ofthe workperformed; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor.

(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul ofall items installed on the aircraft which are requiredto be overhauled on a specifiedtime basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date whenthe next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

9(b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. TheExtent OfReliefThe OverheadFilms seeksAnd TheReason OverheadFilms Seeks TheRelief. 1. Extent Of Relief Overhead Films Seeks And The Reason OverheadFilms Seeks ReliefFrom Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currencyrequirements, to conductthe proposed UAS flight operations for compensation orhire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carrypassengers orpropertyfor compensation orhire. As set forth more fully below, Overhead Films submits that an equivalent level ofsafety will be maintainedbecause no PIC will be allowedto operate the DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergencymaneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, OverheadFilms submits that all flights ofthe DJI Inspire 1 UAS, conductedby the PIC pursuant to the grant ofthis Petition: (1) will be incidental to OverheadFilms' business; and (2) will not carrypassengers orproperty for compensation orhire.

102. Extent Of Relief OverheadFilms Seeks And The Reason OverheadFilms Seeks ReliefFrom Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Overhead Films to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Overhead Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1InstructionManual). Overhead Films seeks the requested reliefbecause the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Overhead Films will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 preflight inspection) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief OverheadFilms Seeks And The Reason OverheadFilms Seeks ReliefFrom Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJI Inspire 1UAS, which utilize abarometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Overhead Films seeks the requested reliefbecause the DJI Inspire 1UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations statedbelow. As
more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Inspire 1UAS are equippedwith a barometric pressure sensor and GPS equipment, which automatically
ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UA onthe heads-up display ofthe GCS.

4. Extent Of Relief OverheadFilms Seeks And The Reason OverheadFilms Seeks ReliefFrom Section 91.15l(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe batterypowered DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of22 minutes. The ALTEK MEDIA GROUP seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe

11battery powered DJI Inspire 1UAS will severely constrain the practicality ofany aerial video or stillphoto flight operations that OverheadFilms proposes to conductpursuantto this Petition.
Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1 UAS, the DJI Inspire 1 operating documents, and Overhead Films' proposed operating limitations, ensure that OverheadFilms will safely operate the batterypowered DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbattery powerto fly for a total duration of22 minutes.

5. Extent Of Relief The OverheadFilms Seeks And The Reason OverheadFilms

Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Overhead Films requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions ofFMRA Section 333 for operation without
an airworthiness certificate. Accordingly, OverheadFilms will use trainedtechnicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Overhead Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Overhead Films will document and maintain all maintenance records for the DJI Inspire 1UAS.

D. The Reasons Why Granting OverheadFilms Request Would Be In ThePublic Interest; ThatIs, How ItWould BenefitThePublic As A Whole. Granting the present Petition will further the public interest by allowing Overhead Films to safely, efficiently, and economically perform aerial video and photography ofconstruction sites, real estate, events and civic landscape over certain areas ofthe United States. Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Overhead Films' proposed operation ofthe DJI Inspire 1 UAS will be realized without implicating any privacy issues.

1. ThePublicWillBenefitFromDecreased Congestion OfTheNAS. The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the
12amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Inspire 1 UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and airpollution, as well as increase the safety oflife andproperty in the air and onthe ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports causedby arriving and departing aircraft will be reduced. The DJI Inspire 1UAS do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video andphotography missions would result in fewer aircraft that mustbe handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. ThePublicWillBenefitFromThe SafetyAndEfficiency OfTheDJIInspire 1 UAS. Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video andphotography, while burning approximately 20-30 gallons perhour ofleadedaviation fuel. The DJI Inspire 1UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by batterypowered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property inthe air and on the ground, which is usually associatedwith traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately 6.47 pounds at their maximum gross weight with diagonal dimension of 17.8 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerialVideo and Photography Operations With TheDJIInspire 1 UAS WillBenefitTheEconomy. In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Overhead Films, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is
one such technologythat not only allows companies greater operational

13flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the DJI Inspire 1UAS, companies such as OverheadFilms, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use ofthe DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. ThereAreNo Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Overhead Films proposed operation ofthe DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., Overhead Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcementnotification, andin accordance withthe Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By TheRule FromWhich OverheadFilms Seeks Exemption. 1. Reasons Why The DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernization and ReformActof2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Overhead Films' operation ofthe DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part21, SubpartH. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create ahazard to users ofthe NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, andnot later than 180days after the date of enactment of thisAct, the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion oftheplan and rulemaking required by section 332 of thisActorthe guidance requiredbysection 334 of thisAct.

14(b) Assessment ofUnmannedAircraft Systems.--ln making the determination under subsection (a), the Secretary shalldetermine, ata minimum-- (1) which types of unmannedaircraftsystems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated areas, andoperation within visual line of sightdo notcreate a hazardto users ofthe national airspace system or the public orpose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is requiredfor the operation ofunmanned aircraft systems identified underparagraph (1). (c) Requirementsfor Safe Operation.--Jfthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch aircraftsystems in the nationalairspacesystem. In seekingthis exemption, OverheadFilms submits that the DJI Inspire 1UAS can operate safely in the NAS pursuantto FMRA Section 333, as demonstratedby: (a) the characteristics ofthe DJI Inspire 1UAS; (b) the pilot certificationrequirement; and (c) the specific operating limitations.

a. The Specifications OfTheDJIInspire 1 UAS DemonstrateIts Safe Characteristics. The DJI Inspire 1 UAS does notcreate a hazardto users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, andoperational capability. i. Technical Specifications OfTheDJIInspire 1 UAS. The technical specifications ofthe DJI Inspire 1UAS are set forth by the DJI Inspire 1 User Manual, attachedhereto as Appendix A. ii. TheDJI Inspire 1 UAS Global Positioning ModesEnable The UAS To Remain Within A Defined OperationalArea. The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire 1 UAS is provided inthe DJI Inspire 1UserManual attachedhereto as AppendixA. iii. TheDJIInspire 1 UAS AreDesigned ForAutomatic Return To Home Point OrHover In TheEventOfLoss OfThe ControlLinkOrNavigation. When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) viaGPS, andwill descendto the takeoffposition and shutdown.

15A complete description ofthe Failsafe Functions ofthe DJI Inspire 1 UAS are set forth in the DJI Inspire 1UserManual, attachedhereto as Appendix A. iv. TheDJIInspire 1 GCSAndIts Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1 GCS and flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is attachedhereto as Appendix A. b. Flight Operations OfDJIInspire 1 UAS IsLimited To TheLine OfSight OfA Certificated Pilotin CommandWithA Safety Observer. Overhead Films video production staff will be the only persons to act as a pilot in command (PIC) ofthe DJI Inspire 1UAS. Additionally, a safety observer will assist him at all times during flight time.

c. Flights OfDJIInspire 1 UAS Will Be Conducted PursuantTo Specific Operating Limitations. In seeking this exemption, Overhead Films proposes to commercially operate DJI Inspire 1 UAS for the special purpose ofconducting aerial video and photography over certain areas of United States, pursuantto the following specific operating limitations. 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video andphotography. 3. The UAS maynotbe flown at anindicated airspeed exceeding 20 knots. 4. The UA mustbe operated at an altitude ofno more than400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported to ATC must be in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

167. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must notperform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedto operate the cameraor other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Priorto each flight the PIC must inspectthe UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operatinguntil the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations mustbe properly documented inthe aircraftrecords.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight mustmake an entryin the aircraftrecords. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements.

1723. The PIC must abort the flight in the eventofunpredictedobstacles or emergencies in accordance withthe operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intendedlandingpoint and landthe UA with 25% batterypowerremaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. All operations shallbe conductedin accordance with airspacerequirements in the ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 26. All aircraft operatedin accordance withthe exemptionmustbe identifiedbyserial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcementofficialupon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS maynotbe operatedbythe PIC from anymoving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that itdoes notpresent anundue hazard, and;

19c. Operations nearer to the PIC, SO, operator trainees or essential persons do notpresent anunduehazardto those personsper § 91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as definedbythe applicable COA mustbe reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) WouldNotAdverselyAffect Safety. Overhead Films submits that the equivalent level ofsafety establishedby Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers andmaintaining appropriate distances from people, vessels, vehicles and structures. Considering OverheadFilms' proposedarea ofoperations, andthe operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Overhead Films submits that the additional manned airmanship experience ofa commercially certificatedpilotwould not correlate to the airmanship skills necessary for OverheadFilms' specificproposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Overhead Films will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC musthave accumulated andlogged, in a manner consistentwith 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of 5 hours ofthose

20hours as a UAS pilot operatingthe same make and model ofUASto be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currencypurposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Overhead Films' proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.5l(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimumhourrequirements to be inclusive ratherthan additive; i.e. 5 hours make andmodel time maybe included in the 10 hours ofmulti-rotortime and the 10 hours maybe included in the total 25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in ExemptionNo. 11062 are appropriate to practice andbuildproficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplishthe required flight time. Duringtraining, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R91.119.

ExemptionNo. 11138 atpage 15. Accordingly, Overhead Films will ensure safe operations bynot allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

21The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Overhead Films will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information ofthe DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Overhead Films' operation ofthe DJI Inspire 1 UAS within visual line ofsight, at orbelow 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiationpoint is automatically establishedby the UAS at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not AdverselyAffect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.P.R. Section 91.15l(b) as a result of(l) the technical specifications ofthe DJI Phantom 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Overhead Films will ensure that it will safely operate the battery powered DJI Inspire 1UAS during daylighthours in VFRconditions, with enoughbatterypower to fly for atotal duration of22 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will
ensure an equivalent level of safety established by 14 C.P.R. Section 91.15l(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remainingbatterypower, and again at approximately 10% remainingbattery

22power. At the critically low battery level, the DJI Inspire 1 UAS will descend and land automatically. Significantly, previous exemptions granted bythe FAA concerning Section 91.151 establish that safetyis not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, OverheadFilms submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because Overhead Films will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the OverheadFilms Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Overhead Films will document and maintain all maintenance records for the DJI Inspire 1UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Overhead Films will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI Inspire 1User Manuals are attached hereto as AppendixA

Likewise, the exemption sought will not adversely affect safetybecause OverheadFilms willuse trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, andpractices prescribedby the operating documents.

Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Inspire 1UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthlymaintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affectedwhen the technical characteristics and operating limitations ofthe UAS are considered.

23In consideration of Overhead Films' proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Inspire 1 UAS, Overhead Films submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. TheFAAMayPrescribeAny Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Overhead Films requests that the FAA prescribe special conditions for the intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that establishedby 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazardto users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS inthe NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety equivalentto that established inthe regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Overhead Films' intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalentto that establishedby 14 C.P.R. Part 21, SubpartH, and 14 C.F.R Sections

2461.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The Rules FromWhich OverheadFilms Seeks Exemption:

Overhead Films seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a) (2), and91.417(a) & (b). A Brief Description Of The Nature Of The Exemption OverheadFilms Seeks:

This exemption will permit Overhead Films to commercially operate an Unmanned Aircraft System (UAS)for thepurpose of conducting aerial video andphotography over certain areas of the UnitedStates.

• Any Additional Information, Views, Or Arguments Available To Support OverheadFilms' Request.

ThisPetition is madepursuantto the FAAModernization andReformActof2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, Overhead Films' request for exemption may be granted pursuantto the authority ofFMRA Section 333 and 14 C.P.R. Part 11, as setforth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authorityfor suchUAS to operate without airworthiness certification. As discussed in detail above, Overhead Films will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security. CONCLUSION As set forth herein, Overhead Films seeks an exemption pursuant to 14 C.P.R. § 11.61 and Section 333 ofthe FAAModernization andReformActof2012 (FMRA), whichwill permit safe operation ofthe DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing Overhead Films to safely, efficiently, and economically operate the DJI Inspire 1UAS commerciallywithinthe NAS.

25WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Overhead Films respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a) (2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Inspire 1 UAS commercially for the purpose ofconducting aerial video and photography over certain areas of the United States. Dated: September4, 2015

OwnerIF ounder OverheadFilms, LLC. 15409 ArabianWay Montverde, FL 34756 352-638-4668 mike@sixmitchells.com

Appendices:

A- Linkto DJIInspire 1Manual: Clickonlinkbelow http://www.dji.com/product/inspire-1/download

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