Carter Thomas

Phone: 1-207-240-1359 

Email: info@goldcoinkingdom.com 

January 19, 2016

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DH 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 C.F.R. 45.23(b); 14 

CFR 61.113 (a) & (b); 14 C.F.R. 91.7 (a); 14 CFR 91.9 (b) & (2); 14 

C.F.R. 91.103; 14 C.F.R. 91.109; 14 C.F. R. 91.119; 14 C.F.R. 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) 

Dear Sir or Madam, 

Pursuant to section 333 of the FAA modernization and Reform Act of 

2012 and 14 C.F.R. Part 11, Gold Coin Kingdom LLC, operator of Small 

Unmanned Aircraft Systems (“sUASs”) for conducting aerial 

photography and videography for private clients and media distribution, 

hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operations of its sUASs, 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 the national airspace system (“NAS”) that 

1) limited 2) predetermined 3) controlled as to access. Approval of this 

exemption fulfill the Secretary of Transportation’s responsibilities to 

“...establish requirements for the safe operations of such aircraft systems 

in the national airspace system.” Section 333(c) of the Reform Act. 
The name and address of the applicant is: 

Gold Coin Kingdom LLC

Carter Thomas

Ph: 207-240-1359 

Email: info@goldcoinkingdom.com 

Address: 1124 Kearny Street

San Francisco, CA 94133

Regulations from which the exemption is requested: 

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 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 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 rule-making requires to 

determine which types of sUASs do not create a hazard to users of the 

NAS or the public or pose a threat to national security in the light of the 

following: 

• sUAS’s size, weight, speed, and operational capability; 
• Operation of the sUAS in close proximity to airports and populated 

areas 

• Operation of the sUAS within visual line of sight of the operator. 

Reform Act Section 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. Section 333 (c). 

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 Section 

401401 of the Act, that includes sUASs, 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 section (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. Section 44701(f) See 

also 49 U.S.C. Section 4471(a)L 49 U.S.C. Section 44704; 14 CFR 

Section 91.203(a)(1). 

Gold Coin Kingdom LLC’s sUASs are rotorcraft, weighting 55 or fewer 

pounds including payload. They operate under normal conditions at a 

speed of no more that 50 knots and have the capability to hover, and 

move in the vertical and horizontal plane simultaneously. They will 

operate only in lines of sight and will operate only within a 

predetermined and closed off property area. Such operation will insure 

that the sUASs will “not create a hazard to users of the national airspace 

system or the public” as per the Reform Act Section 333 (b). 

Given the small size of the sUASs 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 sUASs to comment immediately. Also due to 
the size of the sUASs and the restricted areas in which the relevant 

sUASs will operate, approval of the applications 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 operation, 

and the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including emissions associated with allowing 

sUASs for movie and commercial videography and photography 

operations, 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. 

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 

limitation 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 operation are conducted on 

closed off property under the permission of the property owner or 

property representative. 

These limitations and conditions to which Gold Coin Kingdom LLC 

agrees to be bound when conducting commercial operations under an 

FAA issued exemption include: 

1. The sUAS will weight less than 55 pounds. 

2. Flights will be operated within liens of sight of a pilot and/or 

observer. 

3. Maximum total flight time for each operational flight will be 30 

minutes. Flights will be terminated at 25% battery power reserve 

should that occur prior to the 30 minute time limit. 
4. Flights will be operated at an altitude no more than 400 feet at 

ground level or, not more than 200 feet above an elevated platform 

from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS pilot, 

and the Visual Observer. 

6. sUAS Pilot will be Pilot in Command (PIC. If the PIC deems 

another operator to be qualified with the necessary skills to be the 

PIC, that person cal also be designated as PIC provided they have a 

minimum of 40 hours of flight time with the sUAS. Flights will be 

operated at a lateral distance of at least 50 feet from any inhabited 

structures, buildings, vehicles, vessels, or people not associated 

with the operation or who have not signed a waiver in advance of 

the operation. 

7. A briefing will be conducted in regard to the planned sUAS 

operations prior to each day’s production activities. it will be 

mandatory that all personnel involved with the operational duties 

of the flight within the boundaries of the safety perimeter be 

present for this briefing. 

8. The operator will file an FAA Form 7711-1, or its equivalent, as 

modified in light of the requested exemption, with the appropriate 

local Flight Standards District Office (FSDO). 

9. The operator will obtain the consent of all persons involved in the 

filing and ensure that only consenting persons will be allowed 

within 100 feet of the flight operation, and this radius may be 

reduced to 30 feet based upon an equivalent level of safety 

determination. With the advances permission of the relevant 

FSDO, operations at closer range can be approved. 

10. Pilot and observer will have been trained in operation of sUAS 

generally and receive up-to- date information, with the FSDO. 
11. Observer and pilot will at all times be able to communicate by 

voice, radio, and/or text. 

12. Written and/or oral permission from the relevant property holders 

or property representatives will be obtained. 

13. All required permissions and permits will be obtained from 

territorial, state, county or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies. 

14. If the sUAS loses communications or loses its GPS signal, the 

sUAS will have the capability to return to a pre-determined 

location within the Security Perimeter and land autonomously. 

15. The sUAS will have the capability to abort a flight in case of 

unpredicted obstacles, weather, or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 

Section 91.203 (a)(1) 

Subpart H, entitles Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 

FAR Section 91.203(a)(1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, en exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 222 of the Reform Act. The Federal 

Aviation Act (49 U.S.C. Section 4470 

(f)) and Section 333 of the Reform Act both authorized the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational 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 that 55 pounds when fully 

loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a 

secured area. Unlike other civil aircraft, operation under this exemption 

will be tightly controlled and monitored by both the operator 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 filming. These safety enhancements, which 

already apply to civil aircraft operated in connection with motion picture 

and television production, provide 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 demonstrated 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 C.F.R. Part 45.21 (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,” “light-sport,” 

“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 sUAS, two inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in 

compliance with Section 45.29 (f). 

The equivalent level of safety will be provided by having the sUAS 

marked on its fuselage as required by Section 45.29 (f) where the pilot , 

observer and others working with the sUAS will see the identification of 

the sUAS as “Experimental.” The FAA has issued the following 

exemptions to this regulation to Exemptions numbered 10700, 8738, 

10167, and 10167A. 

14 C.F.R. Section 61.113 (a) & (b): Private Pilot Privileges and 

Limitations: Pilot in Command. 

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 no less 

than 40 hours of flight time with the 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. 

14 C.F.R. Section 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 toe the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the 

size of the aircraft for maintenance and use of safety check lists prior to 
each flight, as set forth in Sections J, L, and Q, an equivalent level of 

safety will be provided. 

14 C.F.R. Section 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 

Section 21.5 of this chapter, unless there is available in the aircraft a 

current approved Airplane of Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

The sUAS, 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 flight 

manual at the ground control point where the pilot flying the sUAS will 

have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemptions numbered 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. Section 91.103: Preflight action. 

This regulation requires each pilot in command to take certain actions 

before flight to ensure the safety of flight. As FAA approved rotorcraft 

flight manuals will not be provided for the aircraft, an exemption will be 

needed. 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 C.F.R. Section 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. 

Small unmanned aerial vehicles 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 on the 2.4 gigahertz spectrum. The

same spectrum is used for video transmission as well. 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 numbered 5778K & 9862A. The 

equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carrier in the aircraft and by the size and speed of the 

aircraft. 

14 C.F.R. Section 91.119: Minimum safe altitudes. 

Section 91.119 established safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less that the 

minimums prescribed, provided the person operating the helicopter 

complies with any router 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 feet above 

ground level with the exception that in circumstances where the sUAS is 

used to survey or photograph a structure whose heigh exceeds 400 feet 

above ground level, the sUAS will not be operated more than 100 feet 

above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, where buildings and people will 

not be exposed to operation without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, 

speed of the sUAS as well as the location where is it operated. No flight 

will be taken without the permission of the property owner or local 

officials. Because of the advance noticed to the property owner and 
participants in the filming activity, all affected individuals will be aware 

of the planned flight operations. Compared to flight operation with 

aircraft or rotorcraft weighting far more than the maximum of 55 pounds 

proposed herein and the lack of flammable fuel, any risk associated with 

these operation is far less than those presently presented with 

conventional aircraft operating at or below 500 feet above ground level 

in the movie industry. In addition, the low-altitude operations of the 

sUAS will ensure separation between these small USA operations and 

the operations of conventional aircraft that must comply with Section 

91.119. 

14 C.F.R. Section 91.121 Altimeter Settings 

This regulation requires that each person operating an aircraft to 

maintain a cruising altitude by reference to an altimeters that is set “...to 

the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS may 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 safety check list and live flight data monitoring, 

confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. Section 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 23 minutes of 

safe flight time. To meet the 30 minute reserve requirement in 14 CFR 
91.151, sUAS flights would be limited to approximately 10 minutes in 

length. Given the limitations on the sUAS’s proposed flight area and the 

location of its proposed operations within a predetermined area, a longer 

time frame for flight in daylight or twilight VFR conditions is 

reasonable. 

The applicant believes that an exemption from 14 CFR Section 

91.151(a) falls within the scope of prior exemption. See Exemption 

number 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with FAR 91.151 (a)). Operating the sUAS, 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 sUAS. Additionally, limiting the sUAS flights to 10 minutes would 

greatly reduce the utility for which the exemption will be granted. 

Application believes that an equivalent level of safety can be achieved 

by limiting flights to 23 minutes or 25% of battery power— whichever 

occurs 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 numbered 2689F, 5745, 10673, and 10808. 

14 C.F.R. Section 91.203 (a) and (b): Carrying Civil Aircraft 

Certification and Registration 

The regulation provides in pertinent part... 

(a) Except as provided in Section 91.715, no person may operate a civil 

aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certification... 
(b) No person may operate civic aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under Section 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55 pounds and it 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 sUAS. 

An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the sUAS 

will have immediate access to them, to the extend they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. 

A representative sample of other exceptions includes Exemptions 

numbered 9565, 9665, 9789,9789A, 9797, 9816A, and 10700. 

14 C.F.R. Section 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): 

Maintenance Inspections. 

These regulations require that an aircraft owner or operator “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. An equivalent level of safety will be 

achieved because these sUASs 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 sUAS can land immediately and will 

be operating from no higher than 400 feet above ground level. The 

operator will ensure that the sUAS 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. 

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the sUAS 

Manufacturer’s manual, as referenced in the Aircraft Operations Manual. 

As provided in the Operations Manual, the operator will ensure that the 

sUAS is in working order prior to initiating flight and perform required 

maintenance needed. 

Additional Views and Information 

The applicant, Carter Thomas DBA Gold Coin Kingdom LLC, has had 

over 60 hours of experience in flying a DJI Phantom 3 Professional 

sUAS. The applicant also conducts free-lance photography and 

videography. The addition of a sUAS opens up new perspectives and 

possibilities when it comes to capturing unique photographs and videos 

in a restricted, sterile environment. 

Applicant seeks an exemption request from the following rules: 14 

C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91.7 (a); 14 CFR 

91.9 (b) & (2); 14 C.F.R. 91.103; 14 C.F.R. 91.109; 14 C.F. R. 91.119; 

14 C.F.R. 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) in order to commercially operate a small unmanned aerial vehicle 

of 55 pounds or less in motion picture and commercial photography and 

videography operations. 

Approval of the exemptions allowing the commercial operation of 

sUASs commercially would enhance safety by reducing risk. 

Conventional commercial videography and photography using jet or 

piston powered aircraft around 4,000 pounds in close proximity to 

people and structures present more extreme safety risks to nearby people 
and structures, especially due to the fact that jet fuel or other fuels are 

being carried on board. These aircrafts must fly to and from the shoot 

location. Contrastingly, a sUAS weighing fewer than 55 pounds and 

powered by batteries eliminates virtually all of the risks given the 

reduced mass and lack of combustible fuels carried on board. The 

sUASs are carried to the shoot location, therefore not exposing nearby 

people and structures to the risks associated with large, manned aircraft 

flights. 

An equivalent level of safety will be reached, provided that all flights 

pertain to the strict conditioned outlines above with the supporting grand 

of exemptions requested, 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 but under 

400 feet above ground level, and in a sterile environment and, as a 

result, are far safer than conventional flight operations conducted with 

turbine helicopters operating in close proximity to the ground and 

people. 

Privacy 

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

property representative or owner’s prior consent and knowledge. 

Filming and photographing will be only of those who have consented to 

being filmed or photographed or otherwise agreed to be in the area 

where filming and/or photographing will take place. 

All flights will occur in accordance with any state or local laws 

regarding privacy. 

Satisfaction of the criteria 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 — provides more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of the applicant’s 
sUAS in the motion picture and commercial videography and 

photography media industry. 

Sincerely, 

Carter Thomas

Gold Coin Kingdom LLC - Owner