9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 L OCHINVAR 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 R equest 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; 91.1 51(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 sough t 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 televisio n 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

saf ety 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!FAA

8 201 5

8 0150!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!ba s ed!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.!9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 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)!717

8 6810

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 i n 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 th e 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 o f 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

ex empting 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!un der!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.!!9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Three

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 a s described in the LMC . Flight Operations Manual (“FOM”) and the Aircraft Flight
Manuals (“AFM”) (hereinafter “the Manuals”). Operations in complia nce 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 supp ort of this application, LMC is submitting, with a request for confidentiality as shown, the
following manuals 4 :

• 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 A ircraft 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 t he 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 em issions 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 interes t. Accordingly, the applicant respectfully requests that the FAA grant the requested
exemption without delay.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 3 Reform!Act!Section!333(b)

4 App licant!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.!!9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Four 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 operat ions 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 limitat ions and conditions to which LMC agrees to be bound when conductin g 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.

• A ll 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 a nd 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 discrepa ncy 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 procedur es 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 up dated 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 Ma nual.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 5 These!conditions!are!reproduced!from!Exemption!11062!through!11067,!11080,!11150!and!11158.!9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Five

• 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 ne cessary 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 airc raft 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 wh o 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 contro ller (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 priva te 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 mu ltirotor). 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 t o 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 d istance from non

- participants in accordance with 14 C.F.R. § 91.119.9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Six

• 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 o f 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 docume nted 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 Stan dards 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 n ecessary 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, a nd 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. I f 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 o f 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).9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Seven

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 pre flight 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 re quirements.

• 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 enforce ment official upon request.9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Eight

• 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 b e 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 P IC.

• 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 u nless 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 Administr ator 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 Int egration 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, accid ent, 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. includ ing, but not limited to, parts 45, 47, 61, and 91.9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Nine

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 commerci al 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 plann ed 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 r isks 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 th e 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 wel l 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 low

altitude operations of the sUAS will ensure separation between these small

- UAS operations and the operat ions 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.9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Ten

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safe ty 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 fir st 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 minut es 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 Lock heed 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 mi nutes 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 minute s 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 Inspecti ons.

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.9301 WILSHIRE BLVD, SUITE 507. BEVERLY HILLS CA 90210 T:310.717.6810 August 10, 2015 Page Eleven

If mechanical issues arise the UAS can land immediately and wil l 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 operato r 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, 11 066, 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 fee t 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 th e 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 her ein. 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 operati ng in close proximity to the ground and people or the use of people to climb the structures to conduct the inspection.