9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810

LOCHINVAR MEDIA CORPORATION

ATTN: Lauder Robinson

9301 Wilshire Blvd. Suite 507

Beverly Hills CA 90210

T: (310) 717-6810

August 10, 2015

Docket Operations, M-30

U.S. Department of Transportation

1200 New Jersey Ave, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Summary Processing: Exemption Request for Lochinvar Media Corporation Under Section 333 of the 

FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. §§ 61.113(a) and (b); 

91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b). 

Exemption under FAA Modernization and Reform Act of 2012 (P.L. 112-95),

Section 333

Dear Sir or Madam:

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

C.F.R Part 11, Lochinvar Media Corporation (“LMC”) operator of Small Unmanned Aircraft Systems 

(“sUASs”) hereby applies for an exemption from Federal Aviation Regulations (FARs) listed below 

under "Basis for Petition" and discussed in Appendix A. Exemption is being sought in order to allow 

LMC to operate its unmanned aircraft systems (“UAS”) commercially for the purpose of aerial 

videography and photography, precision agriculture and environmental management and analysis, aerial 

inspection of land and structures, journalism and news gathering, real estate marketing, and closed-set 

motion picture and television film making and production so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA in an exemption granted 

under either Section 333 or Section 49 U.S.C. § 44701(f). LMC will accept the conditions set forth in 

Exemptions Nos. 11062 and its progeny Nos. 11063, 11064, 11065, 11066, 11067, 11080, 11150 and 

11158 (“the Similar Exemptions). 

We ask for summary approval of this exemption request.1

As this Exemption request is identical to several already granted this Exemption should qualify 

for summary processing as the FAA has already given public notice of and granted similar exemptions. 

As with the approval of the Similar Exemptions, 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. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 LMC notes!that!the!FAA!issued!its!NPRM!in!Docket!FAA8201580150!on!February!15,!2015.!LMC will!accept!the!terms!and!conditions!of!the!

NPRM!in!lieu!of!the!Section!333!application!submitted!herewith,!should!the!FAA!be!willing!to!grant!a!Section!333!exemption!based!upon!the!

NPRM.!If!FAA!is!unwilling!to!grant!a!Section!333!exemption!with those!terms!and!conditions,!LMC requests!that!this!application,!as!submitted,!

be!processed!as!expeditiously!as!possible.!
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August 10, 2015

Page Two

The name and address of the applicant is: 

LOCHINVAR MEDIA CORPORATION

Lauder Robinson

9301!Wilshire!Blvd.!Suite!507

Beverly!Hills!CA!90210

T:!(310)!71786810

Regulations from which the exemption is requested: 

14 C.F.R. § 61.113(a) and (b) 

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a) 

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 407(a)(1)

14 C.F.R. § 409(a)(2)

14 C.F.R. § 417(a) and (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 UASs 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)2. 

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform 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. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 2 Applicant!interprets!this!provision!to!place!the!duty!on!the!Administrator!to!not!only!process!applications!for!exemptions!under!section!

333,!but!for!the!Administrator!to!craft!conditions!for!the!safe!operation!of!the!UAS,!if!it!should!be!determined!that!the!conditions!set!

forth!herein!do!not!fulfill!the!statutory!requirements!for!approval.!!
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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 the Transportation Act 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). 

LMC has more than 35 years experience in the movie and television filming business. LMC

UASs are rotorcraft (eight rotors), weighting 55 or fewer lbs. including payload. They operate, under 

normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the 

vertical and horizontal plane simultaneously. They will operate at altitudes of no more than 400 feet, as 

further explained, and only in line of sight. LMC will be using the MR-14 Aircraft. They will operate 

only within the areas as described in the LMC. Flight Operations Manual (“FOM”) and the Aircraft Flight 

Manuals (“AFM”) (hereinafter “the Manuals”). Operations in compliance with these manuals will insure 

that the sUAS will “not create a hazard to users of the national airspace system or the public”3 and that the 

aircraft will operate in compliance with the conditions set forth in this application. 

In support of this application, LMC is submitting, with a request for confidentiality as shown, the 

following manuals4:

• 14 Channel Computer System 14 SG Instruction Manual, Exhibit 1 (Public) 

• A2 Flight Control System User Manual v1.20, Exhibit 2 (Public) 

• LMC sUAS Flight Operations Manual, Exhibit 3 (Confidential) 

• LMC MR-14 sUAS Aircraft Flight Manual, Exhibit 4 (Confidential) 

Given the small size of the sUASs involved and the restricted 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, the restricted areas in which the relevant 

sUASs will operate and the fact that aircraft will be flown by pilots holding at least a FAA private pilot 

license, 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 battery powered UASs for these functions instead of turbine or gas power aircraft/rotorcraft 

and operations with pilots having at least a private pilot license, 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. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 3 Reform!Act!Section!333(b)

4 Applicant!submits!the!Aircraft!Flight!Manual and!a!Flight!Operations!Manual,!marked!“CONFIDENTIAL”,!as!they!contain!propriety!business

information!that!is!not!released!to!the!public!and!is!protected!under!the!Freedom!of!Information!Act!5!U.S.C.!§!553!etc.!!
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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 filing 

operations conducted with conventional aircraft.5 LMC notes that it has requested that a Certificate of 

Authorization (COA) not be required for flight at or below 400 feet AGL, in Class G airspace and outside 

of 5 nautical miles from the geographic center of airport where a letter of agreement has not been entered 

with the airport management. 

These limitations and conditions to which LMC agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

• The UA must weigh less than 55 pounds, including energy source(s) and equipment. Operations 

will be limited to the aircraft described in the proprietary Manuals: 

• The UA may not be flown at a speed exceeding a ground speed of 50 knots. 

• Flights must be operated at an altitude of no more than 400 feet above ground level (AGL) as 

indicated by the procedures specified in the Operators Manuals. All altitudes reported to ATC 

must be in feet AGL. 

• The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued medical certificate. 

• All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times. 

• The operator will be bound by and follow the Manuals as accepted by the FAA. Any additional 

requirements identified in the final conditions for this Exemption will be added to the Manuals. 

The Manuals will be maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the final exemption and the 

procedures outlined in the Manuals, the conditions and limitations of the Exemption will take 

precedence and will be followed. Otherwise, the operator will follow the procedures as outlined 

in its Manuals. 

• The operator will update or revise its Manual. It will be the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. The 

operator will also present updated and revised documents if it petitions for extension or 

amendment. If the operator determines that any update or revision would affect the basis for 

which the FAA granted this exemption, then the operator will petition for amendment to their 

exemption. The operator will contact the FAA’s UAS Integration Office (AFS-80) with questions 

arising regarding updates or revisions to the Manual. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 5 These!conditions!are!reproduced!from!Exemption!11062!through!11067,!11080,!11150!and!11158.!
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• Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft will not 

operate until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station, if utilized, will be included in the preflight 

inspection. All maintenance and alterations will be properly documented in the aircraft records. 

• Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight in accordance with the Manual. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight. The requirements and procedures for a 

functional test flight and aircraft record entry must be added to the Manuals. 

• The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be 

established and identified in the Manuals. At a minimum, the following must be included in the 

Manual: 

(a) Actuators/Servos 

(b) Transmission (single rotor) 

(c) Powerplant (motors) 

(d) Propellers 

(e) Electronic speed controller 

(f) Batteries 

(g) Mechanical dynamic components (single rotor) 

(h) Remote command and control 

(i) Ground control station (if used) 

(j) Any other components as determined by the operator 

• The PIC will possess at least a private pilot certificate and at least a current third-class medical 

certificate. The PIC will also meet the flight review requirements specified in 14 C.F.R. § 61.56 

in an aircraft in which the PIC is rated on his/her pilot certificate. 

• Prior to operations conducted for the Purpose, the PIC will have accumulated and logged, in a 

manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot and 

at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). 

Prior documented flight experience that was obtained in compliance with applicable regulations 

will be used to satisfy this requirement. Training, proficiency, and experience-building flights 

may also be conducted under this grant of exemption to accomplish the required flight cycles and 

flight time. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations will be considered non-participants, and the PIC will operate the UA with 

appropriate distance from non- participants in accordance with 14 C.F.R. § 91.119. 
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• Prior to operations conducted for the purpose of motion picture filming (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), a 

minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for 

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

Training, proficiency, experience-building, and take-off and landing currency flights can be 

conducted under this grant of exemption to accomplish the required flight time and 90 day 

currency. During training, proficiency, experience-building, and take-off and landing currency 

flights all persons not essential for flight operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

§ 91.119. 

• Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have 

successfully completed a qualification process, as outlined in the operator’s manual. As this is a 

requirement stipulated by the operator, the test must be developed and implemented by a 

qualified person designated at the sole discretion of the operator. A record of completion of this 

qualification process must be documented and made available to the Administrator upon request. 

• Prior to operations conducted for the Purpose, a flight demonstration, administered by an 

operator-approved and -qualified pilot will be successfully completed and documented. This 

documentation will be available for review upon request by the Administrator. Because the 

knowledge and airmanship test qualifications will be developed by the operator, and there are no 

established practical test standards that support a jurisdictional FAA Flight Standards District 

Office (FSDO) evaluation and approval of company designated examiners, the Operator will 

conduct these tests in accordance with the Manual. 

• The UA will not be operated directly over any person, except authorized and consenting 

personnel necessary for the Purpose, below an altitude that is hazardous to persons or property on 

the surface in the event of a UAS failure or emergency. 

• Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

(a) Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations must cease immediately and/or; 

(b) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard, and; 

(c) Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 
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All operations shall be conducted over private or controlled-access property with

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. See, Exemptions 11170, 11172 and 1117 for proposed language. 

• Prior to any flight Operator will only be required to obtain an Air Traffic Organization (ATO) 

issued Certificate of Waiver or Authorization (COA) for flights that are conducted at heights 

greater than 400 AGL; in other than Class G airspace; and closer than 5 miles from the 

geographic center of a non-towered airport, without a letter of agreement with the airport 

manager. If requested, Operator will provide telephonic advanced notice to an ATO or file a 

NOTAM for any flight not requiring a COA. 

• If the UAS loses communications or loses its Global Positioning System (GPS) signal, the UA 

will be programmed to return to a pre-determined location within the security perimeter and land 

or be recovered in accordance with the Manual. 

• The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the Manual. 

• Each UAS operation will be completed within 30 minutes flight time or with 25% battery power 

remaining, whichever occurs first. 

• All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings will be as large as practicable. 

• The operator will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures will be added to the Manual. 

• UAS operated under this exemption will comply with all manufacturer Safety Bulletins. 

• The operator will develop UAS technician qualification criteria. These criteria will be added to 

the Manual. 

• Preflight inspection section in the Manual will be amended to include the following requirement: 

The preflight inspection will account for all discrepancies, i.e. inoperable components, items, or 

equipment, not covered in the relevant preflight inspection sections of the Manual. 

• Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

• The documents required under 14 C.F.R. §§ 91.9 and 91.203 will be available to the PIC at the 

ground control station of the UAS any time the aircraft is operating. These documents will be 

made available to the Administrator or any law enforcement official upon request. 
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• The UA will remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing 

activities, hang gliders, etc.). 

• UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) will not be undertaken. 

• The UAS will not be operated by the PIC from any moving device or vehicle. 

• The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 

• The UA will not operate in Class B, C, or D airspace without written approval from the FAA. The 

UA will not operate within 5 nautical miles of the geographic center of a non- towered airport as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the airport management will be 

made available to the Administrator upon request. 

• Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to the 

Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. Further flight operations will not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 C.F.R. including, but not limited to, parts 

45, 47, 61, and 91. 
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14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113(a) and (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 have a private pilot’s 

license rather than a commercial pilot’s license to operate this small UAS. 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 Manual. The level of safety provided by the 

requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. 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 as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§ 61.113(a) and (b). The FAA has granted exemptions for private pilots to conduct similar 

operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080. 

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 AGL an exemption may be needed to allow such operations. As set 

forth herein, except for the limited conditions stated in the Manual and in condition #3, page 3, 

the UAS will never operate at higher than 400 AGL. 

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, facility owner and local officials. Because of the advance notice to the property 

owner and participants all affected individuals will be aware of the planned flight operations as 

set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting 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 aerial photography industry. In addition, the lowaltitude 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. The FAA has 

granted exemptions to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 

11066, 11067 and 11080. 

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 in at least one operating mode will not 

have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. 
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An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 

11063, 11064, 11065, 11066, 11067 and 11080. 

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 approximately 40 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would be limited to 

approximately 10 minutes in length. 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 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. 

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 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, 10808 and Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080. 

14 C.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (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 flight manual and operating handbook as referenced in the Flight 

Operations and Procedures Manual (FOPM) attached as confidential See Exhibit 3. 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 areas for limited periods of time. 
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If mechanical issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the FOPM, 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. The FAA has granted exemptions for similar operations in Exemptions 11062, 11063, 

11064, 11065, 11066, 11067 and 11080. 

*********

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. §§ 61.113 (a) and (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2); 91.409(a)(2) and 91.417(a) and (b) to operate commercially a small unmanned 

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

Approval of exemptions allowing commercial operations of sUASs for filming for motion picture 

and television work will enhance safety by reducing risk. Conventional 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 6,000 lbs., carrying large amounts of jet A or other fuel (140 

gallons for jet helicopters). Such aircraft must fly to and from the project location. In contrast, a 

sUAS 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 sUAS is carried to the 

target area and not flown. 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 55 lbs., conducted in the strict 

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

exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the 

ground, and in areas that are under the control of the customer for the inspections and, as a result, 

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

proximity to the ground and people or the use of people to climb the structures to conduct the 

inspection.