AERIA L M OBM 

Dear Sirs ... 

We are writing you as the Owners of Aerial MOB who was among the group of the first 333 exemption 

holders that were granted exemptions on September 24, 2014. As you are probably aware, our company 

was instrumental in drafting the very first 333 exemption language in addition to the Motion Picture and 

Television UAS Operations Manual in partnership with the Motion Picture Association of America. Ou 

current exemption expires on September 24, 2016, so we are writin.g you with our position as to why our 

333 exemption should be renewed. 

We realize that your position is that we can simply operate under the new Part 107, but we hope you can 

see why it is crucial that our 333 exemption be renewed and our current, valid GOA's to operate 

under. There are certain entities and industry stakeholders, like Cal ifornia State Parks, CaiTrans, and the 

6 major motion pictures studios that are still going to require that our company have our 333 exemption in 

place and current. Please see more information at 

http://campaign.r20.constantcontact.com/render?m-11 03829990183&ca=cdf95af8-ddab-4bf0-b067-

d8d37ebdaff6. 

These types of entities do not currently recognize Part 1 07 so it is imperative that we have the ability to 

work under the parameters of our 333 exemption in addition to being able to choose to operate under 

Part 107 in the instances that make sense. We understand that we cannot "mix" the parameters of our 

333 exemption with the parameters of Part 107 on any one flight. 

We ask that you please consider our request for renewal of our 333 exemption. Also, given our 

exemption expires on September 24, 2016, this is a very urgent/timely issue. 

Attached are two letters in support of our position. One from the California Film Commission and one 

from the International Cinematographers Guild. 

We are available for a call at any time to discuss. Thank you very much for your consideration. 

Tony Carmean 

Steve Blizzard 

Treggon Owens 

Jonathan Montague 

Aerial MOB 

800-706-4662 

info@aerialmob.com 
NATIONAL OFFICERS 

President 

STEVEN POSTER, ASC 

Vice-President 

HEATHER M. NORTON 

First Vice-President 

PAUL D. VARRIEUR 

Second Vice-President 

JOHN LINDLEY 

Secretary-Treasurer 

EDWARD A AVILA 

Assistant Secretary-Treasurer 

DOUGLAS C. HART 

Sergeant-at-Arms 

CHRISTY FIERS 

• 

National Executive Director 

REBECCA RHINE 

Western Regional Director 

DAVID BEHM 

Eastern Regional Director 

CHAIM L KANTOR 

Central Regional Director 

RUSTY BURRELL 

INTERNATIONAL CINEMATOGRAPHERS GUILD 

LOCAL 600 I.A.T.S.E., NATIONAL OFFICE 

________ www lCG600 com .... _,,_ ---------- NATIONAL OFFICE • 7755 SUNSET BLVD • LOS ANGELES. 0190046 • j323) 876-{)160 • FAX (323,876-1162 

• 80 EIGHTH AVENUE. 14th FLOOR • NEW YORK. NY 10011 • f2 12! 647-7300 •FAX 1212 647-7317 • 901 W.JACKSON BLVD, SUITE 201 • CHIOIGO, IL 60607 • !312 243-3841 • FAX 312}243-4275 

• 1355 PEACHTREE STREET NE, SUiTE I 060 • ATlANTA. GA 30309 • {404 888·0600 • FAX 1404}888-659.3 

·---~---;.;. NEW:;.;,;.,;;;.;::; LfAN :.:.:,::..;; · I.A~---.. -- 504!.:.: 8-..;:_ 42 24..__ ____ _ 

September 7, 2016 

Sirs: 

The International Cinematographers Guild IATSE Local 600 is a national labor union local 

representing UAS aerial cinematography crews on feature films, television series and 

commercials. Five ofthe initial seven aerial operators initially granted 333 exemptions are 

members of our union, as are numerous others across the United States. As their union 

representative, I am writing in support of Aerial MOB's position that their 333 exemption 

should be renewed. 

Currently operating 333 exemption holders are temporarily facing two hurdles in 

transitioning operations to Part 107 rules that are beyond their control. Consequently, the 

loss of 333 exemption status would be devastating to their business and employment 

opportunities. 

The first hurdle is the development of a broad industry understanding of operations under 

Part 107 rules. Our UAS aerial cinematography crews must interface with a wide range of 

employers, state and local permitting agencies, as well as various public safety offices. The 

transition to Part 107 rules requires a significant amount of communications with these 

industry stakeholders and agencies as well their rethinking of policy and the developm~nt of 

new language. Local 600, along with our UAS aerial ~inematography teams, are actively 

involved in these talks, but the process is not yet concluded. These stakeholders include the 

California State Film Commission, Film LA, California State Parks, CaiTrans, and 6 of the major 

motion picture studios. Until these stakeholders have adjusted to Part 107 rules their 

position is that they will be only hiring or issuing filming permits to 333 exemption holders. 

The second hurdle is the establishment of the exemption process under part 107 rules. The 

California State Film Commission has adopted the position that until the exemption process 

under Part 107 rules is up and running to allow for exemptions to fly over people, they will 

continue to recognize only 333 exemption holders. Other agencies may be following their 

lead. 

These issues will be resolved in time. But in the interest of Aerial MOB's ability to continue its 

business and its flight crews to continue to be employed through the transition period, an 

extension of their 333 exemption is imperative. 

Best, 

Business Representative 

International Cinematographers Guild 

IATSE Local600 

28 
7080 Hollywood Blvd. 

Suite 900 

Hollywood, CA 90028 

323.860.2960 

323.860.2972 Fax 

800.858.4749 

filmca@filrn.ca.gov 

V•IWW.fiJrn.C3.90V 

September 8, 2016 

The Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Re: Renewal of333 Exemption 

To Whom It May Concern: 

This letter is being written in support of Aerial Mob's request for renewal of their 333 

exemption. 

By way of introduction, the California Film Commission (CFC) is a state department 

within the Governor's Office of Business and Ecohomic Development. We are tasked 

with retaining and increasing film, TV, commercial and digital production and to see 

that it continues to create jobs and boost business throughout the state. In addition to 

issuing film permits for all state properties, the CFC administers the state's Film & 

TV Tax Credit Program, maintains an extensive location library and offers production 

assistance on a wide variety of issues. We work closely with cities, counties and 

various government agencies to encourage film-fi'iendly practices that help grow our 

state's economy and sustain one of California's signature industries. 

The CFC has been at the forefront of all matters relating to filming with UAS and has 

been involved with the FAA on this issue since before the first seven (7) 333 

exemptions were granted. We are similarly now meeting with local FSDO reps to 

learn more about Part I 07 rules and to disseminate accurate information. 

Because: I 07 rules are less stringent, and we need time to explore safety concerns; we 

don't know yet how long it's going to take for qualified remote pilots to obtain 

waivers to fly over non-pa1ticipants (i.e., cast and crew members) and perforn1 other 

operations currently allowed by 333 operators; 333 exempted operators already have 

experience working on film sets and with film crews, understand the needs, sensitivity 

and language of motion picture, TV and commercial filming; several film studios and 

production entities are (for the time being) only approving UAS operations by 333 

exempted pilots- it's imperative that the exemptions of the original 333 companies, 

such as Aerial Mob, be renewed. It's not only essential to their businesses and 

livelihoods, but also to the industry that has come to rely on their expertise, 

professionalism and level of safety. 

The California Film Commission therefore fully endorses Aerial Mob's application 

for renewal. 

Respectfully yours,