# AER IA L 

# M O B M

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 exp ires on September 24 , 2016 , so we are writin

. g you with our position as to why our 333 exemption shou ld be renewed

. We real ize that your position is that we can simply operate under the new Part 107 , but we hope you can see why it is cruc ial 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 107 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 i nstances 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, thi s 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 Gu i ld

. We are available for a call at any time to discuss. Thank you very much for your cons ideration
. Tony Carmean Steve Blizzard Treggon Owens Jonathan Montague Aerial MOB 800-706
-4662 info @aerialmob

.comNATIONAL OFF I CERS 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 C HAIM L KANTOR Central Regional Director RUSTY BURRELL 

# I NT ERNATIONAL CINEMATOGRAPHERS GUILD LOCAL 600 I.A.T.S.E. , NATIONAL OFFICE www lCG600 com 

# ________....

### _,,_

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### September 7, 2016 Si rs: The International Cinematographers Guild IATSE Local 600 is a national labor un ion local representing UAS aerial ci nematography crews on feature films, television series and commercials. Five ofthe initial seven aerial operators i nitially 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 hurd les 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 i ndustry 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 i nvolved 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 i n the i nterest 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 ofAerial Mob's request for renewal oftheir 333 exemption. By way of introduction, the California Film Commission (CFC) is a state department within the Governor's Office ofBusiness and Ecohomic Development. We are tasked with retaining and increasing film, TV, commercial and digital production and to see that it continues to createjobs 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 ofCalifornia's signature industries. The CFC has been at the forefront ofall 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 I07 rules and to disseminate accurate information. Because: I07 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 ofmotion 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 ofthe 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 ofsafety. The California Film Commission therefore fully endorses Aerial Mob's application for renewal. Respectfully yours,