Ben + Oliver Samuels

4288 New Hope Road

New Hope, PA 18938

Cell: 323-642-8349

website: www.bensamuels.com

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 of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b);

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a);

91.407(a) (1); 91.409(a) (2); 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 CFR Part 11, Ben and Oliver Samuels, operators of Small Unmanned

Aircraft Systems ("sUAS") do hereby apply for an exemption from the Federal Aviation

Regulations ("FAR's") identified below, to allow commercial use of sUAS for the

purpose of aerial photography and closed-set filming, 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 airspace that is 1) limited 2) predetermined and 3) controlled as to access.

Approval of this exemption would thereby fulfill the Secretary of Transportation'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.

Based on the small size of Petitioner’s sUAS, the qualifications and experience of

Petitioners in the motion picture filmmaking business, not to mention their established

collaboration with and adherence to state and local governments, and the restricted,

sterile environment within which Petitioner will operate, the requested exemptions fall

squarely within the zone of safety envisioned by Congress and set forth in Section 333.

Additionally, the enhanced safety achieved by replacing significantly larger manned

aircraft carrying crew and flammable fuel with small UAS carrying no passengers or

crew and operated under the specific guidelines and procedures proposed by Petitioner

gives the FAA good cause to find that the UAS operations enabled by the instant Petition

are in the public interest. Thus, the requested exemptions should be granted.

Also, pursuant to 14 CPR§ 11.87, we request that the FAA not publish this

petition request in the Federal Register and not delay action based on the following:
1. This petition for exemption does not set precedent. Previous identical exemption

requests have been approved.

2. The requested relief is identical to exemptions granted previously, specifically,

Exemption(s) Nos. 11897 (Michael Bethers), 11250 (Videe This! Inc. dba Yeah Drones),

11859 (Steve Fincher), 11109 (Clayco, Inc.) and 11170 (Viafield)), 11310 (Colin

Hinkle), and others.

3. A delay in action on this petition would adversely affect pending requests for aerial

photography operations and result in lost opportunity and wages as several local

businesses, including but not exclusively real estate agents and golf courses, have been

approached or have currently used Amateur photographers providing this service without

FAA exemption. The competitive advantage for unapproved commercial UAS operators

exists and continues to grow every day.

Sincerely,

Ben and Oliver Samuels

4288 New Hope Road

New Hope, PA 18938

I. CONTACT INFORMATION:

Ben + Oliver Samuels

4288 New Hope Road

New Hope, PA 18938

Cell: 323-642-8349

II. THE SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDERAL

REGULATIONS FROM WHICH OLIVER AND BEN SAMUELS REQUEST

EXEMPTION ARE:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14CFR91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)
14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 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 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 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:

• 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 (VLOS) of the Pilot and Observers.

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 §401 01 of the Act; that includes UAS, 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. §44704; 14 CFR §91.203 (a) (1).

Oliver and Ben Samuels’ sUAS is a small rotorcraft aircraft, the DJI Phantom 3,

weighing less than 10 lbs. including sensor payload. They operate their rotorcraft under

normal conditions at a speed of no more than 20 knots, usually 3-5 knots, and have the

capability to hover, and move in the vertical and horizontal plane simultaneously. They

will manually operate only in Visual Line of Sight and will operate only within the

operating parameters as described in the Operating Manual attached as Attachment 1.

Adherence to the Operating Manual will ensure that the sUAS will "not create a hazard to

the national airspace system or the public."

Given the small size and weight of the sUAS 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 sUAS and the areas in which the relevant sUAS 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 significant
public benefit, including enhanced safety, reduction in environmental impact, including

reduced emissions associated with allowing UAS for educational and marketing

operations, (as opposed to full scale aircraft), the granting of the requested exemptions is

in the public interest. Accordingly, the applicant respectfully requests that the FAA grant

the requested exemption without delay.

III. 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 possibly higher level of safety to

operations under the current regulatory structure because the proposed operations

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

conventional aircraft.

These limitations and condition to which Oliver and Ben Samuels agree to be bound

when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 10 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and

aircrew (Spotter I Observer).

3. Maximum total flight time for each operational flight will be 23 minutes. Flights will

be terminated at 25% battery power reserve should that occur prior to the 23 minute limit.

The DJI Phantom 3 is equipped with state-of-the-art features, including the “Return

Home” function, that ensures the drone automatically returns to its point of origin should

it reach its battery reserve.

4. Flights will be operated at an altitude of no more than 400 feet AGL, though most

operations will be conducted within 50 feet of the ground.

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and

Spotter (Observer). In most cases the third aircrew member will serve as the Safety

Officer.

6. The sUAS Pilot will serve as Pilot in Command (PIC).

10. The sUAS will never enter any MOA or Restricted Airspace, nor shall it violate any

TFR as outlined by the FAA. This is further supported by the DJI Phantom 3’s advanced

GPS system and newest software packages, that do not allow the sUAS to enter any

MOA or Restricted Airspace.

11. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior

to each day's flying and recording activities. It will be mandatory that all personnel who

will be performing duties as "flight crew" be present for this briefing.
12. Pilot and Spotter (Observer) will have been trained in operation of sUAS generally

and received up-to-date information on the particular sUAS to be operated as required.

13. Spotter (Observer) and Pilot will at all times be able to communicate by voice or

radio.

14. Written and/or oral permission from the relevant property holders will be obtained.

15. If the sUAS loses communications or loses its GPS signal, the sUAS will have

capability to return to a pre-determined location and land. The DJI Phantom 3 is equipped

with the “Return Home” function, ensuring the sUAS returns to its pre-determined

location and lands with the click of a button.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

IV. DJI PHANTOM 3

Weight (Battery Included) 1280 g

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Decent Speed 3 m/s

Hovering Accuracy:

Vertical +/- 0.1m (when Vision Positiioning is active) or +/- 0.5m

Horizontal +/- 1.5m

Max Speed 16 m/s

Operating Temperature Range 0° C - 40°C

GPS Mode GPS/GLONASS

Max Velocity Less than 8 m/s (when 2m above ground)

Max Flight Time 23 minutes

V. UAS PILOT IN COMMAND

Petitioner’s sUAS pilot in command (PIC) shall have passed the FAA ground school

examination and shall hold at least a third-class medical certificate but shall not be

required to hold a current pilot’s license. Since there are no standards for either private or

commercial UAS pilot certificates, knowledge of airspace regulations acquired from

FAA ground school and dexterity in the control and operation of the sUAS acquired from

actual operation of the aircraft will be the most important factors in establishing an

equivalent level of safety. According to the FAA, “the FAA considers the overriding

safety factor for the limited operations proposed by the petitioner to be the airmanship

skills acquired through UAS-specific flight cycles, flight time, and specific make and

model experience, culminating in verification through testing.” See Exemption No.

11062, Regulatory Docket No. FAA-2014-0352, at p. 18. With those factors in mind,

Petitioner’s UAS PIC shall be required to meet several conditions and limitations:
• The UAS PIC will have accumulated and logged a minimum of 200 flight cycles

and 25 hours of total time as a UAS rotorcraft pilot.

• The UAS PIC will have accumulated and logged a minimum of five hours of flight

time with the specific make and model of the UAS to be utilized for operations under the

exemption and three take-offs and landings in the preceding 90 days.

• Prior to operating, the PIC will be required to pass the knowledge and airmanship

test qualifications developed by Petitioner for the sUAS. There are no established

practical test standards that support a jurisdictional FAA FSDO (“Flight Standards

District Office”) evaluation and approval of company designated examiners. As such, and

given the constraints of the proposed operations, this procedure for testing will not

adversely affect the safety of the NAS.

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §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 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 less than 10 lbs. fully loaded, carries neither a pilot

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

exclusively within a limited radius area as set out in the preflight briefing and VLOS

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

controlled and monitored by both the Operator, pursuant to safety 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 aircraft.

These safety enhancements, which already apply to civil aircraft operated in connection

with video 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 CFR §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", "lightsport," "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 sUAV, 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 sUAV marked on its

fuselage as required by §45.29 (f) where the Pilot, Spotter (Observer) and others working

with the sUAV will see the identification of the sUAS as "Experimental." The FAA has

issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738,

10167 and 10167A.

14 CFR §61.113 (a) & (b):

Private Pilot Privileges and Limitations - Pilot in Command (PIC) 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 have a private pilot's

license rather than a commercial pilot's license to operate this small sUAS. 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 as set forth in the

Operating Manual. The level of safety provided by the requirements included in the

Operating Manual meets that provided by a single individual holding a commercial pilot's

certificate operating a conventional aircraft. The risks associated with commercial

operations contemplated by Part 61 when drafted, that allowing operations of the UAS as

requested with a private pilot as the PIC exceeds the present level of safety achieved by

14 CFR §61.113 (a) & (b).

Because the DJI Phantom 3 will not carry a pilot or passengers, the proposed operations

can be achieved using the safety features of the DJI Phantom 3 and given the fact that the

missions are monitored in real-time, Oliver and Ben Samuels propose that operators of

the DJI Phantom 3 should not be required to hold a commercial or private pilot

certification. The equivalent level of safety will be achieved by having an operator with a

valid driver’s license, 100 hours of flight time with the DJI Phantom 3, and Pilot who has
completed the DJI Phantom 3 manufacturer’s training videos on assembly, maintenance,

pre-flight, flight and landing procedures.

Similar exemptions have been granted to other operations, including Exemption 11859.

14 CFR §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

Operating Manual for maintenance and use of safety checks prior to each flight, as set

forth in the Operating Manual, an equivalent level of safety will be provided.

14 CFR §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 Operating 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, 95658, 10167, 10167A 10602, 32827, and 10700

14 CFR §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 Operating Manual. The PIC will take all actions including

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

14 CFR §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 Exemptions Nos. 5778K &

9862A. The equivalent level of safety provided by the fact that aircraft will be piloted by

a PIC who has previously trained in remote flight areas before attempting flight within

filming distance of structures.

14 CPR § 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, Oliver and Ben Samuels request

authority to operate at altitudes up to 400 ft. AGL; an exemption may be needed to allow

such operations. As set forth herein, the UAS will never operate at higher than 400 ft.

AGL. It will however be operated in a controlled area 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 UAS

as well as location where it is operated. No flight will be taken without the permission of

the property owner. Because of the advance notice to the property owner and participants

in the photographic activity, all affected individuals will be aware of the planned flight

operations as set forth in the Operating Manual. Compared to flight operations with

aircraft or rotorcraft weighing far more than the maximum 10 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 ft. AGL. 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 CPR § 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 will 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 Operating

Manual and Safety Check list, confirming the altitude of the launch site shown on the

GPS altitude indicator before flight.

14 CPR §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 UAS provides approximately 23 minutes of powered flight. To

meet the 30-minute reserve requirement in 14 CFR §91.151, UAS flights would be

impossible. Given the limitations on the UAS's proposed flight area and the location of its

proposed operations within a predetermined area, a longer time frame for flight in

daylight or night VFR conditions is reasonable.

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 reserved 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 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

23 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,

57 45, 1 0673, and 10808.

14 CFR §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 ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (b) 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 10 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 UAS.

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, and should they be issued. 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 CFR §91.405 (a); 407 (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 section 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 Operating manual. An equivalent level of

safety will be achieved because these small UAS 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 ft. AGL. As provided in the Operating Manual, the PIC (operator) will

ensure that the UAS is in working order prior to initiating flight, and perform required

maintenance. 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 CFR 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: D 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14

CFR § 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) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to

operate commercially a small unmanned vehicle (51bs or less) in Educational and

Marketing operations.

Privacy

All flights will occur over private or controlled access property with the property owner's

prior consent and knowledge, or over remote public land. Image capture of people will

rarely take place, but in the event it does, they will have consented prior to being filmed

or otherwise have agreed to be in the area where data collection will take place.

Airborne Image Capture

With regard to airborne filming, Oliver and Ben Samuels adhere to all FAA regulations.

Further Oliver and Ben Samuels’ airborne teams operate under the principals of: Safety

First, Quality Assurance, Accountability, Reporting, and Training. When approved by the

FAA it is Oliver and Ben Samuels’ mandate to treat all UAS operations with the exact

same level of professionalism and seriousness as that of conventional aircraft.
Approval of exemptions allowing commercial operations of UAS in the real estate and

filmmaking industry will enhance safety by reducing risk. Conventional filming

operations, using turbine or piston powered aircraft present the risks associated with

vehicles that weigh in the neighborhood of 2,000lbs.+, carrying large amounts of Jet A or

100 LL (60 gallons for the aircraft primarily hired from vendors in the past by a

production Ben Samuels directed). Such aircraft must fly to and from photographing

location. In contrast, a UAS weighing fewer than 10 lbs. and powered by batteries

eliminates virtually all of the risk given the substantial reduced mass and lack of

combustible fuel carried on board. The UAS is typically transported to the location via

auto or cargo van in a medium sized case and is never flown to set. The UAS will carry

no passengers or crew and, therefore, will not expose them to the risks associated with

manned aircraft.

The operation of small UAS, weighting less than 10 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 piston helicopters or fixed wing

aircraft operating in relatively close proximity to the ground and people.

The primary market of interest for Oliver and Ben Samuels utilizing UAS is the

marketing of real property and golf courses, and the second is private filmmaking.

It is anticipated that the airborne image capture process will be accomplished exclusively

in daytime VFR environments. To capture the highest quality of resolution the majority

of airborne data collections will take place during the 07:00am- 07:00pm (19:00)

window.

V. OLIVER AND BEN SAMUELS

Filmmaking brothers, Oliver and Ben Samuels have collaborated with state and local

governments on numerous occasions. Ben Samuels owns Pennsylvania’s “Watch Me

Film LLC” and directed the feature film Kantemir (Pennsylvania, Kantemir Movie LLC),

starring Robert Englund, filmed in Pittsburgh, PA, and released by Archstone

Distribution. Kantemir Movie LLC utilized aerial helicopter cinematography services of

Cherokee Helicopter Service and it became clear to Ben Samuels how a small UAS

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

far safer than conventional operations conducted with piston helicopters or fixed wing

aircraft operating in relatively close proximity to the ground and people.

Oliver and Ben Samuels co-own “615 The Movie LLC,” and were approved for and

received a 2015 Pennsylvania State Tax Credit to support their feature film 6:15.

Working with Janice Collier, Director of Grants of the Finance and Film Tax Credit,

Commonwealth of Pennsylvania, Tourism, Film, and Marking Office, Oliver and Ben

Samuels adhered to all state and local government requirements, including but not limited
to: full insurance coverage by Philadelphia’s Hirshorn Company, permits and releases for

all personnel and locations involved in production, a state audit by Jovan Goldstein LLC,

and mandatory monthly financial and progress reports.

Oliver and Ben Samuels are committed to adhering to all FAA requirements in the

operation of their sUAS, creating a safe, professional, and approved provider of sUAS

services for clients who are currently being approached by amateur photographers

operating without FAA exemption.

VI. Summary

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 in the aerial photography, real estate, and closed-set filmmaking

industries. Oliver and Ben Samuels are eagerly standing by to support the FAA and UAS

community in its quest to establish proper regulations and protocols for the safe

introduction of unmanned aircraft into the national airspace.

Sincerely,

Ben + Oliver Samuels

4288 New Hope Road

New Hope, PA 18938

Cell: 323-642-8349