July	29,	2015

Marc	Mulry

Owner
Centered	Films 4790	Caughlin	Pkwy	#164
Reno	Nevada	89509

775

- 232

- 6314 marc@centeredfilms.com

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal Aviation	Regulations	from:	14	CFR	21	subpart	H

14	CFR 45.23(b) 14	CFR	61.113(a)	and	(b) 14	CFR	91.7(a) 14	CFR	91.9(b)(2)

14	CFR	91.103

14	CFR	91.109 14	CFR	91.119(c)

14	CFR	91.121 14	CFR	91.151(a) 14	CFR	91.203	(a)	and	(b)	14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)(1)	and	(2)	14	CFR	91.417(a) and	(b)

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

For over	ten	years ,	Centered	Films	has provided	clients	with	expertise	and	knowledge in	the media	production	industry

. We have worked	on	hundreds	of	productions	over	the	past	10	years in	all	types	o f	locations	with	a	perfect	client	and	employee	safety	record.	The	objective	of
Centered	Films and	our	Unmanned	Aircraft	System	( DJI	Phantom	2) aerial	operations	is	to provide	an	affordable,	high

- quality	production	system	for	a	variety	of	governmental,

comm ercial,	public,	and	residential	uses

.

As	owner	of Centered	Films ,	I Marc	Mulry

, have	safely	flown small	RC	electric	quadcopters recreationally	for	approximately	3	years	without	incident.

BACKGROUND

Marc	Mulry seeks	an	exemption	to	operate the DJI	Phan tom	2	system for	compensation	or	hire
within	the	United	States.	The	DJI	Phantom	2	is a vertical	takeoff	and	landing	(VTOL)	Unmanned Aircraft	(UA)	with	display	telemetry	data	built	into	the upgraded	Futaba	14SG radio	transmitter.BASIS	FOR	PETITION

T he	requested	exemptions	will	allow	myself	personally,	and	my	company	to	provide	aerial photography	&	cinematography	for	commercial	clients	while	meeting	necessary	safe	operating parameters	and	regulations	defined	by	the	FAA	&	other	local	and	regional	agenc ies.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”) and	14	CFR	Part	11,	Marc	Mulry,	operator	of	Unmanned	Aircraft	Systems	(UAS),	hereby	applies for	an	exemption	from	the	listed	Federal	Aviation	Regulations	(“FAR s”)	to	allow	commercial operation	of	designated	UAS,	provided	such	operations	are	conducted	within	and	under	the conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333. Commercial	operation	of	an	UAS,	as	described	herein ,	which	are	equipped	with	camera(s)	and sensors,	would	provide	professional	services	in	the	following	areas:

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate, architecture,	land	surveying,	engineering	and	other	relate d	professional	activities. 2.	Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	public events,	cinematography	and	newsgathering. 3.	Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	th e

owners or	local	government	authority.

4 .	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue operations	in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or government	has	requested	it	by	cont ract	or	donation.

5 .	Training	to	persons	individually	or	belonging	to	both	private	and/or	public	organizations	to increase	awareness	and	improve	safety	for	current	and	future	UAS	operations	within	the

NAS.

As	described	fully	below,	the	requested	exemption would	permit	the	operation	of	designated UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	that	would	be	a) limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	exemption	would	increase public	awareness	of	UAS	operat ions	and	enhance	safety	to	aid	in	fulfilling	the	Secretary	of Transportation’s	(the	FAA	Administra tor’s)	responsibilities	to	“... establish	requirements	for	the safe	operation	of	such	aircraft	systems	in	the	national	airspace	system.”

I	plan	to	operate a	UAS,	the	DJI	PHANTOM	2

, which	is	comprised	of	an	unmanned	aircraft	(UA	or Phantom	2).	The	Phantom	2	is	referred	to	as	a	quad

- copter	with	a	maximum	gross	weight	of about	3	pounds.	It	is	equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	b y batteries.	The	UA	has	a	maximum	airspeed	of	16	m/s.

Given	the	small	size	of	the	UAS	involved	and	the	restricted	controlled	environment	within	which they	will	operate,	the	applicant	fits	within	that	zone	of	safety	(an	equivalent	level	of	safety)	in
whic h	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	commercial	operations	of UAS	to	commence	immediately.	Also	due	to	the	size	of	the	UAS	and	the	controlled	areas	in which	the	relevant	UAS	will	operate,	approval	of	the	application	presents	no	nati onal	security issue.	Given	the	following,	the	grant	of	the	requested	exemptions	is	clearly	in	the	public	interest: Marc	Mulry	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	have	thecharacteristics	and	that	operate	with	the	limit ations	listed	herein.	These	limitations	provide	for an	exceptional	level	of	safety	to	operations.	These	limitations	and	conditions	to	which	Marc Mulry	agrees	to	be	bound	when	conducting	commercial	operations	under	an	FAA	issued exemption	including:

1.	Th e	UAS	will	weigh	less	than	55	lbs. 2.	Flights	will	be	operated	within	line	of	sight	of	operator. 3.	Maximum	total	flight	time	for	each	operational	flight	will	be	20	minutes. 4.	Flights	will	be	terminated	at	15%	battery	power	reserve. 4.	Flights	will	be	ope rated	at	an	altitude	of	no	more	than	400	feet	AGL 5.	UAS	operator	will	be	trained	and	certified	in	the	proper	sa fety	and	operations	of	the	UAS. 6.	The	UAS	will	only	operate	within	a	controlled	are a	as	defined	in	the	Procedures.

7 .	The	operator	will	have	be en	trained	in	operation	of	UAS	generally	and	received	up

- to

- date information	on	the	particular	UAS	to	be	operated	as	required.

8 .	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	return
to	a	pre

- determined	location	w ithin	the	Security	Perimeter	and	land.

9 .	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or emergencies.

The	Reasons	Why	Granting	CENTERED	FILMS	Request	Would	Be	In	The	Public	Interest;	That	Is,
How	It	Would	Benefit	T he	Public	As	A	Whole.

Granting	 the	 present	 Petition	 will	 further	 the	 public	 interest	 by	 allowing	 CENTERED	 FILMS	 to safely,	efficiently,	and	economically	perform	aerial	video	and	photography	of	real	estate,	events and	civic	landscape	over	certain	areas	of the	United	States.

Additionally,	 use	 of	 the	 DJI	 Phantom	 2	 UAS	 will	 decrease	 congestion	 of	 the	 NAS,	 reduce pollution,	and	provide	significant	benefits	 to	 the	economy.	Notably,	 the	benefits	of	CENTERED FILMS’	proposed	operation	of	 the	DJI	Phantom	2	UAS

, wi ll	be	 realized	without	implicating	any privacy	issues.

1.	The	Public	Will	Benefit	From	Decreased	Congestion	Of	The	NAS.

The	 DJI	 Phantom	 2	 UAS	 are	 battery	 powered	 and	 serve	 as	 a	 safe,	 efficient,	 and	 economical
alternative	to	the	manned	aircraft	traditio nally	utilized	to	obtain	aerial	imagery.	By	reducing	the amount	 of	manned	 aircraft	 needed	 to	 perform	 aerial	 acquisitions,	 an	 exemption	 allowing	 the use	of	a	DJI	Phantom	 2	UAS	would	 reduce	 the	amount	of	manned	aircraft	in	 the	NAS,	 reduce noise	and	air	pollu tion,	as	well	as	increase	the	safety	of	life	and	property	in	the	air	and	on	the ground.

Furthermore,	 by	 reducing	 the	 number	 of	 manned	 aircraft	 operating	 in	 the	 NAS,	 congestion around	 airports	 caused	 by	 arriving	 and	 departing	 aircraft	 will	 be	 reduced.	 The DJI	 Phantom	 2 UAS	 do	 not	 require	 an	 airport	 to	 takeoff	 or	 land.	 Likewise,	 a	 reduction	 of	 manned	 aircraft conducting	aerial	video	and	 photography	missions	would	 result	in	 fewer	aircraft	 that	must	 be handled	by	air	traffic	control	during	the	ground,	takeoff ,	departure,	arrival,	and	landing	phases of	flight	operations.2.	The	Public	Will	Benefit	From	The	Safety	And	Efficiency	Of	The DJI	Phantom	2 UAS.

Conducting	 aerial	 acquisitions	 with	 the	 DJI	 Phantom	 2	 UAS,	 instead	 of	 manned	 aircraft,	 will greatly	ben efit	the	public	by	drastically	reducing	the	levels	of	air	and	noise	pollution	generated during	 traditional	 aerial	 video	 and	 still	 photography	 flight	 operations.	 By	 using	 battery	 power and	electric	motors,	 the	DJI	 Phantom	 2	UAS	 produce s no	air	 pollution,	an d	is	 the	most	viable environmentally	conscious	alternative	to	the	cabin	class,	six	cylinder	internal	combustion	engine aircraft	that	are	typically	utilized	for	aerial	video	and	photography,	while	burning	approximately

20

- 30	 gallons	 per	 hour	 of	 leaded	 aviat ion	 fuel.	 The	 DJI	 Phantom	 2	 UAS,	 while	 reducing	 the carbon	footprint	of	aerial	acquisitions,	also	eliminates	noise	pollution,	as	the	UAS	are	propelled by	battery	powered	electric	motors,	rather	than	an	internal	combustion	engine.

By	using	 the	DJI	 Phantom 2	UAS	 to	perform	aerial	acquisitions,	 the	 substantial	 risk	 to	life	and property	 in	 the	 air	 and	 on	 the	 ground,	 which	 is	 usually	 associated	 with	 traditional	 manned aircraft	flight	operations,	will	be	substantially	reduced	or	completely	eliminated.	Aside	fro m	the lack	 of	 flight	 crew	 members	 located	 onboard	 the	 aircraft,	 the	 DJI	 Phantom	 2	 UAS	 (weighing approximately	3	pounds	at	their	maximum	gross	weight	with	diagonal	dimension	of	23.2	inches, and	with	no	fuel	on	board),	has	less	physical	potential	for	collate ral	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	of	approximately	42	feet,	a length	of	34	feet,	and	a	fuel	capacity of	180	gallons).

3.	Performing	Aerial	Video	and	Photography	Operations	With	The	DJI	Phantom	2	UAS	Will Benefit	The	Economy.

In	addition	to	being	safe	and	efficient,	the	DJI	Phantom	2	UAS	are	also	an	economical	alternative to	 using	 manned	 aircraft	 to	 c onduct	 similar	 aerial	 operations.	 As	 such,	 operation	 of	 the	 DJI Phantom	 2	 UAS	 will	 allow	 United	 States	 based	 companies,	 like	 CENTERED	 FILMS,	 to	 remain competitive	and	contribute	 to	growth	of	 the	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	Phantom 2	UAS	is one	such	technology	that	not	only	allows	companies	greater	operational	flexibility	compared	to manned	aircraft,	but	provides	such	 flexibility	without	 the	high	operational	cost	of	a	 traditional
manned	aircraft.

By	 operating	 the	 DJI	 Phantom	 2	 UAS ,	 companies	 such	 as	 CENTERED	 FILMS,	 can	 remain competitive	 and	 profitable,	 and	 therefore,	 provide	 greater	 job	 stability	 to	 employees	 and contractors,	which	will	ultimately	contribute	to	growth	of	the	U.S.	economy.	Improved	financial performance	of	U.S.	com panies,	through	commercial	use	of	the	DJI	Phantom	2	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 competitiv e	both	in	the	United	States	and	abroad.4.	There	Are	No	Privacy	Issues.

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	been	conducted	for	decades, CENTERED	FILMS’	proposed	operation	of	the	DJI	Phantom	2	UAS	will	not	implicate	any privacy issues.	Specifically,	 the	DJI	Phantom	2	UAS	will	be	operated	only	in	compliance	with	operating
documents (i.e., DJI	Phantom	2	Instruction	Manual)	which requires	property	owner	in volvement as	 well	 as	 local	 law	 enforcement	 notification,	 and	 in	 accordance	 with	 the	 Federal	 Aviation Regulations,	including	the	minimum	altitude	requirements	of	14	C.F.R.	§	91.119.

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the requested	exemption and	are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	need	for	an equivalent	level	of	safety.	I	look	forward	to	working	with	your	office.	Please	contact	me	at	any
time	if	additional	information	or	clarifications	ar e	needed.

Thank	you	for	your	consideration	in	this	matter.

Sincerely,

Marc	Mulry

775

- 232

- 6314 marc@centeredfilms.com

Link	to	DJI	Phantom	2	Manual:		Click	on	link	below

http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf