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 FAA 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 Modernization 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 commercial videography industry for closed set 

filming, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUASs, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. 

 

 As described more fully below, the 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 enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements 

for the safe operation of such aircraft systems 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 52312 
Regulations 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 Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned 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 making this determination, the Secretary is 

required to determine which types of UASs 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: 

 • The UAS’s size, weight, speed, and operational capability; 

 • Operation of the UAS in close proximity to airports and populated areas; and 

 • Operation of the UAS within visual line of sight of the operator. 

 Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, 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 grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

term is defined under §40101 of the Act, that includes sUASs, from the requirement that 

all civil aircraft must have a current airworthiness certificate. 

 The Administrator may grant an exemption 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 exemption 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-rotorcraft that have the capability to hover, and move 

in the vertical and horizontal plane simultaneously. They will operate only in line of sight 

and will operate only within a predetermined 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 professionally 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 navigational (GPS and 

altimeter) systems. This creates a more reliable and robust product than systems using 

parts/components from multiple manufacturers, 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/notifications/warnings. All of our sUAS aircraft weigh 

between 9 to 10 pounds (flight ready) and 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 sUAS movement) with a camera mounted that is 

used for filming. The camera gimbals operate 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 speed of 45mph (roughly 40 knots). We have 

set lower limits for our maximum speeds depending 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 will 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 provided by the FAA or 

local governments; and manuals for all equipment. There are four manuals for the ALTA 

sUAS equipment, two for the ALTA itself and 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 involved and the restricted sterile environment 

within which they will operate, the applicant falls 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 areas in which the relevant sUASs 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 operations, and 

the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and 

commercial videography 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 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 operate 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 because the proposed operations are conducted on 

closed off property under the permission 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 appropriate FSDO. Only upon approval of our 

flight plans from all entities will we agree to, and conduct, any operation within five (5) 

miles of an airport. 

 

 These limitations and conditions to which 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 operational flight will be 20 minutes. Flights will 

 be terminated at 30% battery power reserve 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 consist of the sUAS Pilot, and the Visual 

 Observer. 

6. sUAS Pilot will be Pilot in Command (PIC). The PIC will be a FAA licensed airman 
 with at least a Sport Pilot Certificate (current 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 training time with the specific sUAS equipment 

 LW UAS operates. In addition, the PIC will have a minimum of 40 hours of additional 

 experience flying sUAS equipment 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 flight logs of all PICs it employs, and 

 provide full transparency to the FAA regarding the logs and records of these PICs. 

7. Flights will be operated at a lateral distance 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 waiver 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 personnel involved with the 

 operational duties of the flight within the boundaries of the safety perimeter be present 

 for this briefing. 

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

 requested exemption, with the appropriate local Flight Standards District Office. 

10. The operator will obtain the consent of all persons involved in the filming and ensure 

 that only consenting persons 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 permission 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 received up-to-date information on the particular 

 sUAS to be operated. 

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

 license. 

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

 and/or text. 

14. Written and/or oral permission from the 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 law 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 Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 
Applicant, 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 certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity 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 certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

The sUAS to be operated hereunder is 50 lbs. or less fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. Unlike other 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 motion picture and television 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 demonstrates 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 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 registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator 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 sUAS will have no airworthiness 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. Given the size of the sUAS, two-inch lettering 

will be impossible. The word “Experimental” 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 pilot, observer, and others working with the 

sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued the 
following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 

10167A. 

When the FAA issues a Registration number for 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): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial 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 Certificate (current 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 training time with the specific 

sUAS equipment LW UAS operates. In addition, the PIC will have a minimum of 40 

hours of additional experience flying sUAS equipment 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 flight 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 coordinated in advance. Currently there are no 

pilot licenses that are specific for UAS operators, 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 commercial operation, one that 

sets high standards on the quality 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 unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance, and use of safety check lists 
prior 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 flight and navigation systems. 

 4. Transmitter: Confirm radio transmitter has sufficient charge, and is both 

 working properly and receiving telemetry from the sUAS; confirm all switches 

 are in pre-flight mode. 

 5. Surroundings/Flight Area: Conduct one last visual inspection of the take-off 

 surroundings and area of airspace sUAS will be operating in. Confirm all 

 people in the surrounding areas are associated with the filming being done. 

 6. Take-off Announcement: Before motors are started the PIC will announce to a 

 designated Representative (person of authority) of the film crew that sUAS is 

 ready to take-off. Only after the Representative has notified 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 flight electronics; after any pre-flight or in 

 flight equipment errors that occur not resulting from environmental conditions; 

 very first thing of any commercial operations day before filming begins; if 

 there are any concerns about environmental 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 available 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 the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 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 approved 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 transport of sUAS aircraft to a different location, 

or if the PIC determines the sUAS equipment is not functioning properly, 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 inspected 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 followed by confirmation of no errors with 

the flight and navigation systems. 

- Upon completion of all other pre-flight inspection tasks, a test flight will be conducted 

to confirm all systems are working properly and 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 these tasks are not able to be completed, then 

the sUAS will not be airworthy until appropriate maintenance is done and the PIC 

successfully completes another pre-flight inspection. 

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

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction 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 via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 

9862A. The equivalent level of safety is provided 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 altitudes 
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated 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 sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 feet AGL, or not more than 

200 feet above an elevated platform from which 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 that 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 restricted 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. Because 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 aircraft or rotorcraft 

weighting far more than the maximum 50 lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations 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 sUAS will ensure separation between these 

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 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, 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 Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for 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 be 
possible due to the reserve requirement being equal to the maximum flight time. Given 

the limitations on the sUAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer 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 (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 reserve fuel, does not 

engender the type of risks that 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 essentially 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 aircraft unless the airworthiness 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 sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 
14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft 

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 repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply 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 Manufacturer's Manual, and will be performed 

by employees of LW UAS following the guidelines 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 flight, perform required 

maintenance, and keep a log of any maintenance 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 the equivalent level of safety. 

Privacy 

All flights will occur over private or controlled 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 otherwise 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 sUAS equipment can provide to the film and 

television industries. It not only provides new cinematography capabilities, but also 

increased safety over current and past practices that used larger and more dangerous 

equipment. Our company wants to have the highest 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 commercial manufacture and use of sUAS equipment will create 

more jobs for the United States 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 determined that publication is needed: 
 Applicant seeks an exemption from the following rules: 

 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & 

 (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 

 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) 

 and 91.417 (a) & (b) to operate commercially a small unmanned vehicle 

 (50 lbs or less) in motion picture, television, and commercial videography 

 operations. 

Approval of exemptions allowing commercial operations of sUASs in the film industry 

will enhance safety by reducing risk. Conventional 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 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 must fly to and from the film 

location. In contrast, a sUAS weighing fewer 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 will 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 less than 50 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity 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 motion picture, television, and commercial 

videography industry. 

Sincerely, 

Lane Wooder 

LW UAS LLC 

Owner and Operator