Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 1 of 9 

### July 2 7 2015 U. S. Department of T

ransportation Docket Management Sy stem 1200 New Jersey

Av e., SE Wa shington, DC 20590 To whom it may

concern: Submitted and related to: 01) Exemption Request

- Section 333 of the F AA Reform Act Pursuant to Sectio n 333 of the F AA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F .R. Part 1 1, Green Moss Grows Media , LLC, doing business as and publicly branded as UC OREGON TV , an operator of Small Unmanned Aircraft Sy stems (UAS or UA Vs ) equipped to cond

uct aerial photograph y for the motion picture and television and content production, creation industry for scripted closed set filming, hereby applies for an exemption from the listed Federal Av iation Regulations (F ARs) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by

the F AA as required by

Section 333.1 or other pertinent sections as applied by federal law

. As described more full y below, the reque sted exemption would permit the operation of small, unmanned and relativel y inexpensive UAS under controlled 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 presentl y using conventional aircraft. Approval of this exemption would thereb y enhance safet y and fulfill the Secretary of Tr ansportation ’ s (the F AA A dministrator) responsibilities to establish requirements f or the safe operation of such aircraft s ys tems in the national airspace s ys tem. Section 333(c) of the Reform Act. The name and address of the applicant is: Eddie V Garcia, CEO Green Moss Grows Media, LL C, d / b / a UC OREGON TV 1904 Adams Av enue La Grande, O R 97850 (541) 316

- 5650 ucoregontv@gmail.com

December 1, 2014Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 2 of 9 U. S. Department of T ra nsportation Dock et Management S ystem 1200 New Jersey Ave., SE Washington, DC 20590 Re : Exemption R equest S ection 333 of the FAA Reform Act 

### To whom it may

concern: Pursuant to Section 333 of the F AA Modernization and R eform Act of 2012 (the Reform Act) and 14 C.F .R. P art 11, Green Moss Grows Media , LL C, doing business as UC OREGON TV , operator of Small U nmann ed Aircraft Systems (“ U AS”) equipped to conduct aerial photography for the motion picture and t elevision and content creation industry for scripted closed set filming, hereby applies for an ex emption from the listed F ederal Aviation Regulations (“F ARs”) t o allow commercial operation of its U AS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the F AA as required by Section 333. 1 As described more fully below , the requested ex emption would permit the operation of small, unmanned and relatively inexpensive UAS under controlled 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 fi lm and television industry presently using con ventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secr etary of Tra nsportation’ s (the FAA Administrator ’s ) r esponsibilities to “...establish requirements for the safe oper at ion of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.
**The name and address of the applicant is:** 

### Eddie V Garcia, CEO Green Moss Grows Media, LL C, dba UC OREGON TV 1904 Adams Av enue La Grande, OR 97850 (541) 3 16

- 5650 ucoregontv@gmail.com

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

- Issue a Certificate of W aiver for Motion Picture and T elevision F ilming and par ts thereof

.Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 3 of 9 

## FA A UAS Exemption Request Application This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform A ct. This law directs the Secretary of T ra nsportation to consider wheth er certain unmanned aircraft systems may operate saf

ely in the national airspace system (NAS) before completion of the rule

- making required under Section 332 of the R eform Act. In making this determination, the Secretary is required to determine which type s of UAS do not create a hazard to users of the ( NAS ) or the public or pose a threat to national security in light of the following: I. The U AS’ s siz e, weight, speed, and operational capability; Ii. Operation of the UAS in close proximity to Airports, He liports, Po wer Plants, Fuel Depots and populated areas; and Ii. Operation of the UAS within visual line of sight of the operator

. Refo rm Act § 333 (a). Lastly , if the Secr et ary determines that such vehicles “may operate safely in the national airspace sy stem (NAS) , the Secretary shall establish requirements for the safe oper ation of such aircraft in the national airspace system. ” Id. §333(c) (emphasis added)

. The F ederal Aviation Act expressly grants the FAA the authority to issue ex emptions. This statut ory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. Applicant hereby interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the U AS, if it should be determined that the conditions set forth h erein do not fulfill the statutory requirements for approval. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or an y sections 44 702

- 447 16 of this title if the Administr ato r finds the ex emption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44 704; 14 CFR §91.203 (a) (1). Green Moss Grows Media LLC ’s U AS are multi rotor craft, weighting 55 or f ewer lbs. including its pay load. They operate, und er normal conditions at a speed of no more than 50 mph and have the capability to hover , and move in the vertical and horiz ontal plane simultaneously . They will oper ate **only** in line of sight and will oper ate **only** within the sterile area described in the GM GM LLC Operating Manual, (hereinafter “ GMGMGOM ”). Such oper ations will insure that the UAS will “not create a haz ard to users of the national airspace system or the public. ” Given the small siz e of the UAS involved and the restricted sterile environment within which they will oper ate, the applicant falls squarely within that z one of safety (an equivalent level of safety) in which Congress en visioned that the FAA must, by ex emption, allow commercial operations of UAS to commence immediately . Also due to th e siz e of the UAS and the restricted areas in which the relevant UAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed oper ations, and the significant public benefit, including enhanced safety , r eduction in en vir onmental impacts, including reduced emissions associated with allowing UAS fo r movi e and television operations, the grant of the requested exemptions is in the public interest. Accordingly , the applicant respectfully requests that the FAA grant the requested exemption without dela y.Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 4 of 9 

## FAA UAS Exemption Request Application
**AIR CRAFT A**  **ND EQUIV**

**ALENT LEVEL OF SAFETY** The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or eve n higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe movie and television filming operations conducted with con ventional aircraft. These limitations and conditions to which Green Moss Grows Media , LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include ; Green Moss Grows Media LLC will utiliz e a Phantom 2 V ision U AS and reserve the opportunity to contract a l icensed UAS operator

, pursuant to F

AA rules and its own COA certificate to shoot production shots for the exclusive use of Green Moss Grows Media, LLC. Our Phantom 2 V ision is compliant as follows:
1. The U AS will weigh less than 55 lbs. 2. Flights will be ope rated within line of sight of a pilot and/or observer

. 3. Maximum total flight time for each oper ational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be oper a ted at an altitude of no more than 2 00 feet AGL or , not more than 200 feet above an elevated platform from which filming is planned. STRICTL Y ENF ORCED. 5. Minimum crew for each operation will consist of the U AS Pilot, the V isual Observer

. 6. UAS pilot will ope rate under the guidance and oversight of an FA A licensed airman with at least a private pilot ’s certificate and third class medical. 

### 7. UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the UAS Pilot, who possess the necessar y PIC qualifications, is also present on set (i.e. the A erial Coordinator), that person can also be designated as PIC. 8. The U AS will only operate within a confined “ Area of Operation” as defined in the law

. 9. A briefing will be conducted in regard to the pla nned UAS oper ations prior to e ach day ’s p roduction activities. It will be mandatory that all per sonnel who will be performing duties within the boundaries of the area of oper ations be present f

or this briefing. 10. The oper ator will file a FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards Dis trict Office (FSDO ) as required under law

. All filings shall be ke pt in a file fo r (2) two years and for inspection. 11. The oper ator will obtain the co nsent of all persons in vo lved in the filming and ensure that only consenting per sons will be allowed within 100 feet of the flight operation, and this radius ma y be reduced to 30 feet based upon an equivalent level of safety as described in the oper at ions

. Wi th the advanced permission of the relevant FSDO, oper ations at closer range can be approved. 12. The operator will submit a written Plan of Ac tivities to the FSDO (5) FIVE days before the proposed shoot as required

. 13. All Green Moss Gr ows Media LLC crew wil l have been tr ained in oper ation of UAS generally and re ceived up - to
- date information on the particular UAS to be operated as required

. 14. Observer and pilot will at all times be able to communicate by voice , Motorola closed cir cuit in

- ear handheld devices. 15. Wr itten and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate g overnmental agencies if necessary and re quired under commensurate law(s).Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 5 of 9 

## FAA UAS Exemption Request Application
17. If the UAS loses communications or loses its GPS signal, the UAS will have capability to r eturn to a pre - determined location within the Se curity Perimeter and land. 18. The UAS will have the capability to abort a flight in case of unpredicted obs tacles or emergencies or change in weather or other altering effect that endangers the production or public.
**14 C.F .R. P**  **art 21, Subpart H: Airworthine ss Certificates 14 C.F** **.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the siz e and limited operating area associated with the aircraft to be utiliz ed by the Applicant, an ex emption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Ref orm Act. The F ederal Aviation Act (49 U.S.C.§44 701 (f)) and Se ction 333 of the Reform Act both authoriz e the FAA to exempt aircraft from the requirement f or an airworthiness certificate, upon consideration of the siz e, weight, speed, operational capability , and proximity to airports, power plants, fuel depots and pop ulated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer , tha n a con ventional aircr aft (fix ed wing or rotorcraft) oper ating with an airworthiness certificate without the restrictions and conditions proposed. The U AS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger , carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the General Operating Manual. U nlik e other civil aircraft, operations under this ex emption will be tightly controlled and monitored by bo th the operator , pursuant to the Manual’ s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the ar ea of operation as is now done with con ventional filming. The F AA will ha ve advance no tice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property owners than con ventional operations co nducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly , application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its siz e, speed of operation, locat ion of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
**14 C.F .R. § 45.23 (b). Marking of the Aircraft**  The regulation requires: When marks include only the Roman capital letter "N" and the r egistration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the oper ator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station , in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as t he UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the siz e of the UA

V, two
- inch lettering will be impossible. The word “Experimen tal” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be pr ovided by having the UA V mark ed on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UA V will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8 738, 10167 and 10167A.Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 6 of 9 

## FA A UAS Exemption Request Application
**14 C.F .R. § 61.113 (a) & (b): Private Pilot Privi**  **leges and Limitations: Pi lot in Command.**  Sections 61.113 (a) & (b ) limit private pilots to non

- commercial operations **.** Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to operate under the supervision of a private pilot ’s license holder rather than a commercial pilot ’s license holder . U nlik e a con ventional aircraft that carries the pilot and passengers, the U AS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the GOM. The level of safety provided by the requirements included in the GOM exceed that provided by a single individual holding a commercial pilot ’s cert ificate operating a con ventional aircraft. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as reques ted with a private pilot in a supervisory role aiding the PIC exceeds the present level of safety achieved by 14 C.F .R. §61.113 (a) & (b). **14 C.F .R. §91.7(a): Civil aircraft airworthine**  **ss.** The regulation requires that no person may operate a civil aircra ft unless it is in airworth y c ondition. As ther e will be no airworthiness certificate issued for the aircr aft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the siz e of the aircraft and the req uirements contained in the Gener al Operating Manual for maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided. **14 C.F .R. § 91.9 (b) (2): Civil Aircr** **aft Flight Manual in the Aircraft.** Section 91.9 ( b) (2) provides: No per son ma y oper ate a U .S.

- registered civil aircraft ... (2) F or which an Airplane or R otorcraft Flight Manual is not required by §21.5 of this chapter , unless there is available in the aircraft a current approved airplane or R otorcraft Flight Manual, approved manual material, markings, and placards, or an y c ombination thereof

. The U AS, given its siz e and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by k eeping the flight manual at the ground control point where the pilot flying the U AS will have immediate access to it. The F AA has issued the following exemptions to this regulation: Ex emption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 3282 7, and 10700. **14 C.F .R. § 91.103: Prefligh**  **t action** This regulation requires each pilot in command to tak e certain actions befor e flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircr aft an exemption will be needed. An equivalent level of safety will be provided as set forth in the Aircraft Operating Manual (AOM) for each UAS. The PIC will tak e all actions as described in the GOM and AOM.Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 7 of 9 

## FA A UAS Exemption Request Application
**14 C.F .R. §91.109: Flight instruction**  : Section 91.103 provides that no person may operate a civil aircraft (except a man ned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.
**UAS** and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FA A has approved ex emptions for flight tr aining without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exe mption Nos.5 77 8K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the siz e and speed of the aircraft. **14 C.F .R. §91.119: Minimum saf** **e altitudes**
Section 91.119 esta blishes safe altitudes for oper ation of civil aircraft. Section 91.119 (d) allows helicopters to be oper ated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA . As this exemption is for a UAS that is a helicopter and the ex emption requests authority to operate at altitudes up to 400 Above Ground Level (AGL,) or not more than 200 above an elevated platform from which filming is planned, an ex emption may be needed to allow such oper ations. However , Green Moss Grows Media LLC will ONL Y fly below 200 feet at all times. As set f orth herein, ex cept for the limited conditions stated in the General Operating Manual, the UAS will never operate at higher than 400 AG L. It will however be operated in a restricted area with security perimeter , where buildings and people will not be exposed to oper ations without their pre

- obtained notification and consent when required. The equivalent level of safety will be achieved given the siz e, weight, speed of the UAS as well as the location where it is operated. No flight will be tak en without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the fil ming activity , all affected individuals will be aware of the planned flight operations as set forth in the GOM. Compared to fligh t oper at ions with aircraft or ro to rcraft weighing far more than the maximum 55lbs. proposed herein and the lack of flammable fu el, an y risk associated with these oper ations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry . In addition, the low

- altitude operations of the UAS will ensure separation between thes e small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 C.F .R. §91.121 Altimeter Settings**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an alti meter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS ma y not ha ve a barometric altimeter , but instead a GPS altitude read out, an exemption may be needed. An equivalent le vel of safety will be achieved by the operator , pursuant to the General Operating Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 C.F .R. § 91.151(a): Fuel Requirements for Flig**  **ht in VFR Conditions** Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and fo recast weather co nditions) there is enough fuel to f ly to t he first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to f ly after that fo r at l east 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 8 of 9 

## FA A UAS Exemption Request Application Green Moss Grows Media LLC requests relief from Section 91.151 due to the battery life that powers the UAS. T ypical aerial batteries provide approximately 40 minutes of powered flight. T o meet the 30

- minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length . In relief of the 30

- minute reserve, given the limitations on the UAS’ s proposed area of predetermined operation, a longer time frame f or flight might be reasonable. As per our internal rules, Operating Manual, flight times will never exceed 75% of the ba ttery(s) consumption or 25% reserve; whichever happens first. We will also secure a 2 nd battery for unit. Applicant believes that an ex emption 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 a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of r eserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the siz e and speed of the small UAS. Additionally

, limiting UAS flights to 10 minutes would greatly reduce the utility for which the ex emption will be g ra nted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing z one fr o m an ywhere in its limited operating area. Similar exemptions have been granted to other oper ations, including Exemptions 2689F , 5745, 10673, and 10808. **14 C.F .R. §91.203 (a) and (b): Carrying Civi**  **l Aircr aft 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 has within it the following: (1) An appropriate and current airworthiness certificate. . . 

### (a) No per son ma y oper ate a civil aircraft unless the airwort hiness certificate required by paragraph (a) of this section or a special flight authoriz ation issued under §91.7 15 is displayed at the cabin or cockpit entrance so that it is legible to passeng er s or cr ew . The U AS fully loaded weighs no more than 55 lbs and is operated without an on

- board pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. Each UAS oper ated by Gr een Moss Grows Media, LLC will be r egistered with the FAA and all docum entation carried by the PIC.
An equivalent level of safety will be achieved by ke eping these documents at the ground control point wher e the pilot flying the U AS will have immediate access to them, to the extent they are applicable to the UAS. The FAA has issued numerous ex emptions to this regulation. A representative sample of other exceptions includes Ex emption Nos. 9565, 9665, 9789, 9789A, 9 797, 9 79 7A, 9816A, and 10700. **14 C.F .R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspecti**  **ons** These regulations require that an aircraft operator or owner “shall have that aircr aft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies re paired as prescribed in part 43 of this chapter ...,” and others shall inspect or maintain the aircraft in compliance with Part 43.Green Moss Grows Media LLC F AA Section 333 Exemption Application Page 9 of 9 

## FAA UAS Exemption Request Application Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the guidelines set forth in the Maintenance manuals designed for each UAS. An equivalent level of safety will be achieved because the se small U ASs are very limited in siz e and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provi ded in the GOM, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and k eep a log of an y maintenance performed. Moreover , the oper ator is the per son mos t familiar with the aircraft and best s uited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety
. Pur suant to 14 C.F .R. Part 11, the following summary is provided for publication in the F ederal Register , should it be determined that publication is neede d: 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 (55lbs or less) in motion picture and television operations. Approval of exemptions allowing commercial operations of UAS in the film and content creation industr y will enhance safety by reducing risk. Con ventional film operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks as sociated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 g allons for jet helicopters, e.g.). Such aircraft must fly to and from the film location. In contrast, a UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the film set and not flown. The UAS will carry no passenger s or cr ew and, ther efore, will not expose them to the risks associated with manned aircraft flights. The operation of small U ASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions reques ted herein, including ex empting the applicant from the requirements of P art 21 and allowing commercial operations. These lightweight aircraft operat e at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than con ventional operations conducted with turbine helicopters operating in close pro ximity to the ground and people. **Privacy** All flights will occur over private or controlled access property with the property owner ’s prior consent and knowledge. F ilming will b e of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will tak e place. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- siz e, weight, speed, operating capabilities, prox imity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the gr ant of the requested ex emptions allowing commercial operation of applicant ’s U AS in the motion pictur e and television industry pursuant to the Manual appended hereto. 

### Thank you,

Eddie V Garcia