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

July 27 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

To whom it may concern:

Submitted and related to:

01) Exemption Request - Section 333 of the FAA Reform Act

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Green Moss Grows Media, LLC, doing business as and publicly branded as UC OREGON 

TV, an operator of Small Unmanned Aircraft Systems (UAS or UAVs) equipped to conduct aerial 

photography 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 Aviation Regulations (FARs) 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 FAA as required by Section 333.1 or other 

pertinent sections as applied by federal law.

As described more fully below, the requested exemption 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 

film and television industry presently using conventional aircraft. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator) 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:

Eddie V Garcia, CEO

Green Moss Grows Media, LLC, d/b/a UC OREGON TV

1904 Adams Avenue

La Grande, OR 97850

(541) 316-5650

ucoregontv@gmail.com

December 1, 2014
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 2 of 9

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

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 

11, Green Moss Grows Media, LLC, doing business as UC OREGON TV, operator of Small Unmanned Aircraft Systems 

(“ UAS”) equipped to conduct aerial photography for the motion picture and television and content creation industry for 

scripted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) 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 FAA as required by Section 333.1

As described more fully below, the requested exemption 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 film and 

television industry presently using conventional aircraft. 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:

Eddie V Garcia, CEO

Green Moss Grows Media, LLC, dba UC OREGON TV

1904 Adams Avenue

La Grande, OR 97850

(541) 316-5650

ucoregontv@gmail.com

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a

Certificate of Waiver for Motion Picture and Television Filming and parts thereof.
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 3 of 9

 FAA UAS Exemption Request Application

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 rule-making required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which 

types 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 UAS’s size, weight, speed, and operational capability;

Ii. Operation of the UAS in close proximity to Airports, Heliports, Power Plants, Fuel Depots and populated 

areas; and

Ii. 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 (NAS), 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, 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 Administratorto not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of 

the UAS, if it should be determined that the conditions set forth herein 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 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 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Green Moss Grows Media LLC’s UAS are multi rotor craft, weighting 55 or fewer lbs. including its payload. 

They operate, under normal conditions at a speed of no more than 50 mph and 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 the sterile area described in the GMGM LLC Operating Manual, (hereinafter “GMGMGOM”). Such 

operations will insure that the UAS will “not create a hazard to users of the national airspace system or the public.”

Given the small size of the UAS 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 UAS to commence immediately. Also 

due to the size 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 

operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions associated with allowing UAS for movie 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 delay.
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 4 of 9

 FAA UAS Exemption Request Application

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 

represent a safety enhancement to the already safe movie and television filming operations conducted with 

conventional 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 utilize a Phantom 2 Vision UAS and reserve the opportunity to contract a licensed 

UAS operator, pursuant to FAA rules and its own COA certificate to shoot production shots for the exclusive use of 

Green Moss Grows Media, LLC.

Our Phantom 2 Vision is compliant as follows:

1. The UAS will weigh less than 55 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 30 minutes. Flights will be terminated at 25% battery 

power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 200 feet AGL or, not more than 200 feet above an elevated 

platform from which filming is planned. STRICTLY ENFORCED.

5. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer.

6. UAS pilot will operate under the guidance and oversight of an FAA 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 

necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as 

PIC.

8. The UAS will only operate within a confined “Area of Operation” as defined in the law.

9. A briefing will be conducted in regard to the planned UAS operations prior to each day’s production activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the area of operations 

be present for this briefing.

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

the appropriate Flight Standards District Office (FSDO) as required under law. All filings shall be kept in a file for (2) 

two years and for inspection.

11. 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 as described in the operations. With the advanced permission of the relevant FSDO, 

operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO (5) FIVE days before the proposed shoot 

as required.

13. All Green Moss Grows Media LLC crew will have been trained in operation of UAS generally and received 

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 circuit in-ear handheld 

devices.

15. Written 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 governmental agencies if necessary and required under 

commensurate law(s).
Green Moss Grows Media LLC FAA 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 return to a 

pre-determined location within the Security Perimeter and land.

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

weather or other altering effect that endangers the production or public.

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, power plants, fuel depots and populated 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, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS 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. Unlike other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by both 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 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 UAS, 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 UAS will have no airworthiness certificate, an exemption may be needed as the UAS will 

have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the 

size of the UAV, 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 UAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAV will see the identification of the UAS as 

“Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 

10167 and 10167A.
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 6 of 9

FAA UAS Exemption Request Application

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 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. Unlike a conventional aircraft that carries the pilot and passengers, the UAS 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 certificate operating a 

conventional 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 

requested 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 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 and the requirements contained in the 

General 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 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 UAS, 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 pilot flying the UAS 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. An 

equivalent level of safety will be provided as set forth in the Aircraft Operating Manual (AOM) for each UAS. The PIC 

will take all actions as described in the GOM and AOM.
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 7 of 9

FAA 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 manned 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 

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 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 UAS that is a helicopter and the 

exemption 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 exemption may be needed to allow such operations. 

However, Green Moss Grows Media LLC will ONLY fly below 200 feet at all times. As set forth herein, except for the 

limited conditions stated in the General Operating Manual, the UAS will never operate at higher than 400 AGL. 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 notification and consent when required.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 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 as set forth in the GOM. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the maximum 55lbs. 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 UAS 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 UAS 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 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 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.”
Green Moss Grows Media LLC FAA Section 333 Exemption Application Page 8 of 9

FAA UAS Exemption Request Application

Green Moss Grows Media LLC requests relief from Section 91.151 due to the battery life that powers the 

UAS. Typical aerial batteries provide approximately 40 minutes of powered flight. To 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 for flight might be reasonable. As per our internal rules, Operating Manual, flight times will never exceed 75% 

of the battery(s) consumption or 25% reserve; whichever happens first. We will also secure a 2nd battery for unit.

Applicant believes that an exemption 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 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, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be 

granted.

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 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) and (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. . .

(a) 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 UAS 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 

operated by Green Moss Grows Media, LLC will be registered with the FAA and all documentation carried by the PIC.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where 

the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 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.
Green Moss Grows Media LLC FAA 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 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 UAS can land immediately and will be operating from no higher than 

400 feet AGL. As provided in the GOM, the operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator 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.

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 

(55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commercial operations of UAS in the film and content creation 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, 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 passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.

The operation of small UASs, 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 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.

Privacy

All flights will occur over private or controlled access property with the property 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.

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 UAS in the motion picture and television industry pursuant to the Manual appended hereto.

Thank you,

Eddie V Garcia