Lane Wooder LW UAS LLC - Owner/Operator

T: +1 770 331 5918

lanewooder@gmail.com

December 16, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the F AA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C. F.R. 45.23 (b); 14 C.F.R. 21; 14 C.F.R. 61.113 (a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103 (b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151 (a); 14 C.F.R. 91.203 (a) & (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Mode rnization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, LW UAS LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial videography and photography for the motion picture, television, and commerc ial videography industry for closed set filming, hereby applies for an exemption fr om the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of it s sUASs, so long as such operations are

conducted within and under the conditions outl ined herein or as may be established by the FAA as required by Section 333.

As described more fully below, th e requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in the NAS that is 1) limited 2) predetermined 3) controlled as to access. Approval of this exemption would thereby e nhance safety and fulfill the Secretary of Transportation’s (the FAA Admi nistrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft system s in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

LW UAS LLC

Attn: Lane Wooder

Ph: 770-331-5918 Email: lanewooder@gmail.com

Address: 207 Vine Street Morley, IA 52312Regulations from which the exemption is requested:

14 C.F.R. 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Ac t. This law directs the Secretary of Transportation to consider whether certain unm anned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required

under Section 332 of the Reform Act. In ma king this determination, the Secretary is required to determine which types of UASs do no t create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, sp eed, and operational capability; • Operation of the UAS in close proximity to airports and pop ulated areas; and • Operation of the UAS within visu al line of sight of the operator.

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

The Federal Aviation Act expressly gr ants the FAA the authority to issue exemptions. This statutory authority by its te rms includes exempting ci vil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that

all civil aircraft must have a cu rrent airworthiness certificate.

The Administrator may grant an exemp tion from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exempti on in the public interest. 49 U.S.C. § 44701 (f)

See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1).LW UAS's sUASs are multi-ro torcraft that have the capability to hover, and move in the vertical and horizontal plane simultaneous ly. They will operate only in line of sight and will operate only within a predetermi ned and closed off property area under the permission of the property representative. Such operations will insure that the sUAS will

“not create a hazard to users of the national airspace system or the public” as per the Reform Act Section 333 (b).

All of our sUAS aircraft are professiona lly manufactured by FreeFly Systems. The model name is “ALTA”, and it is a multi -rotor hexacopter made mostly of carbon fiber with small amounts of plastic and uses both steel and aluminum fasteners. The airframes of our copters are the same size, with a width/diameter of 114.5 centimeters and a height of 50.8 centimeters. All aspects and components of the ALTA are developed and manufactured by FreeFly, including the flight control and na vigational (GPS and altimeter) systems. This creates a more re liable and robust product than systems using parts/components from multiple manufacturer s, especially since the hardware and software are consistent and specifically developed for each other. For control of the sUAS aircraft we employ radio systems manufactured by Futaba (www.futabarc.com) that utilize the 2.4 GHz frequency band, and provide telemetry back to the operator detailing important status readings/notificati ons/warnings. All of our sUAS aircraft weigh between 9 to 10 pounds (flight ready) a nd have a maximum payload of 15 pounds. Therefore, the maximum weight any of our sUAS aircraft could be flying at is 25 pounds. The payload we carry are camera gimbals (mounts for cameras that allow remote control of pan and tilt that is independent of the s UAS movement) with a camera mounted that is used for filming. The camera gimbals opera te remotely using the 2.4 GHz frequency band, and also transmit a video signal on the 5.8 GHz frequency band to the Gimbal Operator (not the sUAS Operator).

Our sUAS aircraft have a maximum sp eed of 45mph (roughly 40 knots). We have set lower limits for our maximum speeds de pending on payload: 40mph for payloads of 10 pounds or less, 35mph for any payloads higher than 10 pounds. Since our sUAS aircraft are helicopters they can hover in the air, so they have a minimum airspeed of zero. Most operation of the sUAS aircraft wi ll require speeds between 0 and 25mph, and faster speeds will only be used when operating in wide-open areas with no obstacles.

All paperwork and certificates necessary for commercial operation of sUAS will be kept on person by the PIC. This will include, but not limited to: Section 333 Exemption from FAA; MPTOM; Certificate of Waiver or Authorization; Pilot’s certificate; medical certificate or driver’s license; sUAS registration documents (when supplied by the FAA); any additional permits /authorizations provi ded by the FAA or local governments; and manuals for all equipm ent. There are four manuals for the ALTA sUAS equipment, two for the ALTA itself a nd two for the Futaba radio control system:

- ALTA_Manual_RevC_03.pdf

- ALTA_Setup_Guide_Rev5.pdf

- Futaba_14SG_Manual.pdf

- Futaba_R7008SB_Manual.pdf These manuals will be attached as separate documents to the filing of this petition.Given the small size of the sUASs involve d and the restricted sterile environment within which they will operate, the applicant fa lls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due

to the size of the UASs and the restricted ar eas in which the relevant sUASs will operate, approval of the application presents no nationa l security issue. Given the clear direction in Section 333 of the Reform Act, the author ity contained in the Fe deral Aviation Act, as amended; the strong equivalent level of sa fety surrounding the proposed operations, and the significant public benefit, including enha nced safety, reduction in environmental impacts, including reduced emissions associ ated with allowing UASs for movie and commercial videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant re spectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that opera te with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure becau se the proposed operations are conducted on closed off property under the permissi on of the property owner or property representative.

Our normal operations will be outside of five (5) miles from any airport. If we are asked to operate within five (5) miles of an airport we will contact the airport's manager and control tower with all flight plans, as well as the FAA through our normal filing of a Form 7711-1 (or its equivalent) with the a ppropriate FSDO. Only upon approval of our flight plans from all entities will we agree to, and conduct, any opera tion within five (5) miles of an airport.

These limitations and conditions to wh ich LW UAS agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh no more than 50 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operationa l flight will be 20 minutes. Flights will be terminated at 30% battery power re serve should that occur prior to the 20 minute

limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned. If a structure being filmed or photographed has a height which exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the highest point on that structure. 5. Minimum crew for each operation will cons ist of the sUAS Pilot, and the Visual

Observer. 6. sUAS Pilot will be Pilot in Command (PIC ). The PIC will be a FAA licensed airmanwith at least a Sport Pilot Certificate (c urrent on flight review requirements), or any other classification the FAA recognizes as meeting it’s pilot requirements. The PIC

will have a minimum of 20 hours of trai ning time with the sp ecific sUAS equipment LW UAS operates. In addition, the PIC w ill have a minimum of 40 hours of additional experience flying sUAS equipment of th e same class as what LW UAS operates. The experience of the PIC will be certif ied by LW UAS through background checks and, if necessary, testing. LW UAS will maintain flight logs of all PICs it employs, and provide full transparency to the FAA re garding the logs and r ecords of these PICs. 7. Flights will be operated at a lateral distan ce of at least 100 feet from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiv er in advance of the operation. 8. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production activities. It will be mandatory that all pers onnel involved with the operational duties of the flight within th e boundaries of the safety perimeter be present for this briefing. 9. The operator will file a FAA Form 7711-1, or it s equivalent, as modified in light of the requested exemption, with the appropria te local Flight Standa rds District Office. 10. The operator will obtain the c onsent of all persons involved in the filming and ensure that only consenting pe rsons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. With the advanced perm ission of the relevant FSDO, operations at closer range can be approved.

11. PIC and Visual Observer will have been trained in the operation of the specific sUAS equipment used by LW UAS, and receiv ed up-to-date information on the particular sUAS to be operated.

12. The PIC must hold a current FAA airman me dical certificate or a valid U.S. driver’s

license.

13. Visual Observer and PIC w ill at all times be able to communicate by voice, radio,

and/or text. 14. Written and/or oral permission from th e relevant property holders or property representatives will be obtained. 15. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local la w enforcement, fire, or other appropriate governmental agencies.

16. If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will have the capability to return to a pre- determined location within the Security Perimeter and land autonomously. 17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthin ess Certificates, establishes the procedural requirements

for the issuance of airworthin ess certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by theApplicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificat e, upon consideration of the size, weight, speed, ope rational capability, and proxim ity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness cert ificate, in the restricted environment and under the conditions proposed will be at leas t as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate w ithout the

restrictions and conditions proposed.

The sUAS to be operated hereunder is 50 lbs. or less fully loaded, carries neither a pilot nor passenger, carries no expl osive materials or flammabl e liquid fuels, and operates exclusively within a secured area. Unlike ot her civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with moti on picture and televisi on production, provide a greater degree of safety to the public and property owners than conventional operations

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria dem onstrates that there is no credible threat to national security posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flam mable 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 registration number is displayed on limited, restricted or light-spor t category aircraft or experimental or provisionally certificated aircraft , the operator must also displa y on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters no t less than 2 inches nor more than 6 inches high, the words "limited", "restr icted", "light-sport", "experimental", or "provisional", as applicable.

Even though the sUAS will have no airworth iness certificate, an exemption may be

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Give n the size of the sUAS , two-inch lettering will be impossible. The word “Experiment al” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilo t, observer, and others working with the sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued thefollowing exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and

10167A. When the FAA issues a Registration number fo r our sUAS aircraft it will be placed on the fuselage where it is visible to anyone working with the sUAS.

14 C.F.R. § 61.113 (a) & (b): Pr ivate Pilot Privileges and Limitations: Pilot in

Command.

Sections 61.113 (a) & (b) limit pr ivate pilots to non-commerci al operations. Because the sUAS 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 be a FAA licensed airman with at least a Sport Pilot Certificat e (current on flight review requirements), or any other classification the FAA r ecognizes as meeting it’s pilot requirements. The PIC will have a minimum of 20 hours of training time with the specific sUAS equipment LW UAS operates. In a ddition, the PIC will have a minimum of 40 hours of additional experience flying sUAS e quipment of the same class as what LW UAS operates. The experience of the PIC will be certified by LW UAS through background checks and, if necessary, testing. LW UAS will maintain f light logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records

of these PICs. The PIC must hold a current FAA airman medical certificate or a valid

U.S. driver’s license.

The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS by a PIC meeting the standards of LW UAS (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and c oordinated in advance. Currently there are no pilot licenses that are specific for UAS ope rators, and no current FAA sanctioned pilot license of any type requires training with, and knowledge of, UAS equipment greater than the requirements LW UAS uses to certify its PICs. Our company hopes the FAA develops a new Pilot License specific for UAS and sUAS commercia l operation, one that sets high standards on the quali ty of pilots and increases the professionalism of our emerging industry. If the FAA does this, LW UAS' s PICs will be some of the first to file for these licenses. Our company would also be happy to work with the FAA to help develop the standards for new licenses, and any other regulations the FAA is developing for UAS operation.

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unle ss it is in airworthy

condition. As there will be no ai rworthiness certificat e issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft fo r maintenance, and use of safety check listsprior to each flight (summaries listed below) , an equivalent level of safety will be provided. Summarized Safety Checklists:

1. Aircraft: All adjustment points will be checked for tightness; all motors and props will be inspected; all wiring will be double checked; all systems will be powered up and checked for errors. 2. Battery: Confirmation will be made that batteries are fully charged and installed/connected properly. 3. Calibration: Pre-flight motor/gyro calibration followed by confirmation of no

errors with the fli ght and navigation systems.

4. Transmitter: Confirm radio transmitter has sufficient charge, and is both working properly and receiving tele metry from the sUAS; confirm all switches are in pre-flight mode. 5. Surroundings/Flight Area: Conduct one la st visual inspectio n of the take-off surroundings and area of airspace sUAS will be operating in. Confirm all people in the surrounding areas ar e associated with the filming being done.

6. Take-off Announcement: Before motors are started the PIC will announce to a designated Representativ e (person of author ity) of the film crew that sUAS is ready to take-off. Only after the Re presentative has notifie d all persons within the surrounding areas, and confirmed to PIC that they have clearance to lift-off,

will the motors be started and the sUAS will conduct its operation. 7. Test Flight: A test flight will be conducted: after any disassembly/reassembly; after replacement of any motors or f light electronics; after any pre-flight or in flight equipment errors that occu r not resulting from environmental conditions; very first thing of any commercia l operations day before filming begins; if there are any concerns about envir onmental conditions and potential issues with the flight path.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S. -registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is availa ble in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size 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 keeping the flight manual at the ground control point where the PIC flying th e sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA appr oved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

Prior to the first flight of the day, after trans port of sUAS aircraft to a different location, or if the PIC determines the sUAS equipmen t is not functioning pr operly, an inspection of the following things will take place by the PIC: - All adjustment points on sUAS will be checked for tightness. - All stress points will be inspecte d for signs of damage or distress. - All motors and propellers will be inspected. - All wiring will be double checked. - All systems will be powered up and checked for errors. - All batteries will be inspected for any damage or signs of distress.

- Confirmation will be made that batteries are fully charged and installed/connected properly. - Confirm radio transmitter: has sufficient charge ; that all switches are in pre-flight mode; and is both working properly and receiving telemetry from the sUAS. - Conduct pre-flight motor/gyro calibration fo llowed by confirmation of no errors with the flight and navigation systems. - Upon completion of all other pre-flight inspec tion tasks, a test flight will be conducted to confirm all systems are working properly a nd there are no errors or signs of problems with operation of the sUAS equipment.

Once all of these tasks have been successfully completed the sUAS aircraft will be determined airworthy by the PIC. If any of th ese tasks are not able to be completed, then the sUAS will not be airworthy until appr opriate maintenance is done and the PIC successfully completes anot her pre-flight inspection.

14 C.F.R. § 91.109: Flight instruction:

Section 91.109 provides that no person may operate a civil ai rcraft (except a manned free balloon) that is being used for flight instruc tion unless that aircraft has fully functioning dual controls. sUASs 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 vi a radio communications. The FAA has approved exemptions for flight training without fully functional dual contro ls for a number of aircraft and for flight instru ction in experimental aircra ft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is pr ovided by the fact that neither a pilot nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe altitudesSection 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less th an 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 sUAS that is a helicopter and the exemption requests authority to operate at al titudes up to 400 feet AGL, or not more than 200 feet above an elevated platform from wh ich filming is planned, an exemption may be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 feet AGL with the exception th at in circumstances where the sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. It will however be operated in a rest ricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. B ecause of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with airc raft or rotorcraft weighting far more than the maximum 50 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operati ons is far less than t hose presently presented

with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conv entional 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 altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, conf irming the altitude of the launch site shown

on the GPS altitude indi cator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind a nd forecast weather conditions) there is enough fuel to fly to the first point of in tended landing, and, assumi ng normal cruising speed – (1) During the day, to fly after that fo r at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the sUAS provides no more than 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would not bepossible due to the reserve requirement bei ng equal to the maximum flight time. Given the limitations on the sUAS’s proposed fli ght area and the location of its proposed operations within a predetermined area, a l onger time frame for flight in daylight or twilight VFR conditions is reasonable.

Applicant believes that an exemption from 14 C.F.R. § 91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (all owing 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 le ss than 30 minutes of reserve fuel, does not engender the type of risks th at Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. Additionally, the limitations created by this requirement for sUAS flights would e ssentially make null any utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 30% of battery power— whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil airc raft unless the airwor thiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 50 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sa mple of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.14 C.F.R. § 91.405 (a); 407 (a)(1 ); 409 (a)(2); 417 (a) & (b): Ma intenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in s ubpart E of this part and sha ll between required inspections, except as provided in paragra ph (c) of this section, have discrepancies repaired as prescribed in part 43 of this ch apter...,” and others sh all inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance and inspections

will be done in accordance with the sUAS Ma nufacturer's Manual, and will be performed by employees of LW UAS following the guideli nes and practices provided to us by the sUAS Manufacturer. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that the sUAS is in working order prior to initiating fl ight, perform required maintenance, and keep a log of any mainte nance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide th e equivalent level of safety.

Privacy

All flights will occur over private or cont rolled access property with the property representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or othe rwise have agreed to be in the area where filming will take place. All flights will occur in accordance with any state or local laws regarding privacy.

Additional Views and Information

LW UAS has realized the amazing benefits s UAS equipment can provide to the film and television industries. It not only provides new cinematography capabilities, but also increased safety over current and past practi ces that used larger and more dangerous equipment. Our company wants to have the hi ghest levels of safety and professionalism, and one thing essential to this is achieving a path to commercial licensing with the FAA. We believe this will help reduce unsafe practices, discourage improper uses, and improve public perception. The commerci al manufacture and use of sUAS equipment will create more jobs for the United St ates and help boost the economies in many sectors, and we want to help the FAA in creating regulations that will allow incorporation of UAS devices into our country's airspace for commercial use.

********* Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed:Applicant seeks an exempti on 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); 91.4 07 (a)(1); 91.409 (a )(2); 91.409 (a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (50 lbs or less) in motion picture, television, and commercial videography operations.

Approval of exemptions allowing commercial op erations of sUASs in the film industry will enhance safety by reducing risk. Conven tional film operations, using jet or piston power aircraft, operate at extremely low altit udes just feet from the subject being filmed and in extreme proximity to people and struct ures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters.) Such aircraft mu st fly to and from the film location. In contrast, a sUAS weighing fewe r than 50 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel

carried on board. The sUAS is carried to the film set. The sUAS w ill carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting le ss than 50 lbs., conduc ted in the strict conditions outlined above, will provide an equi valent level of safety supporting the grant of the exemptions requested herein, incl uding exempting the applicant from the requirements of Part 21 and allowing commerc ial operations. These lightweight aircraft operate at slow speeds, close to the ground, a nd in a sterile environment and, as a result, are far safer than conventional operations c onducted with turbine he licopters operating in close proximity to the ground and people.

Satisfaction of the criteria provided in Section 333 of th e Reform Act of 2012--size, weight, speed, operating capabilities, proxim ity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS equipment in the moti on picture, television, and commercial videography industry.

Sincerely,

Lane Wooder

LW UAS LLC Owner and Operator