August 10, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Wa shington, DC 20590



### 1. Contact Name and Information:

All A Dream Media, LLC Shin Lee, Owner 1105 Sepulveda Blvd. #C

- 203 Phone: (310) 508

- 1135 Email: alladreammedia@gmail.com



### 2. Sections of 14 CFR Requiring Exemption

14 C.F.R. 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 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 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)



### 3. Extent of Relief Seeked and the Reason for ReliefAll A Dream Media is writing pursuant to the FAA Modernization and Reform Act of

2012 and the procedures contained within 14 C.F.R. 11, to request that All A Dream Media, an owner and operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations ( “FARs”) listed below so that All A Dream Media may operate a small lightweight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, All A Dream Media is experienced in testing and flying UAS for recreational purposes. All A Dream Media will be using professional grade quadcopter UASs (DJI Phantom 3 Professional and DJI Inspire 1) equipped with an internal, extremely high quality camera on a removable 16GB (max 64GB) m icro SD card. The Phantom 3 camera shoots full Ultra HD 4K video with 4096x2160 pixel resolution at 24/25 frames per second and 3840x2160 pixel resolution at 24/25/30 frames per second. The DJI Inspire 1 shoots full Ultra HD 4K video as well, at 24

- 60 fps. These models are equipped with the intent for aerial videography/cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the California area, and enhance real estate listing vid eos for real estate agents and homeowners; following exemption and approval by the FAA. These outlined purposes will help promote local economic growth and employment as well as enhance academic research experience for the southern California region.

I, Shin Lee, have flown UASs without incident for four years. W ith continued commitment to safety with each flight, All A Dream Media’s exemption request would permit operation of lightweight (less than 5 lbs), unmanned (piloted by remote control) UAS(s) in t ightly controlled and limited airspace. All A Dream Media will operate the UAS in predetermined areas away from general public, airports, helipads and vehicular traffic for community videos, and within property boundaries for individual homeowner real esta te listing videos/ photos. Currently, similar lightweight, remote controlled UASs are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. In contrast, every pilot of All A Dream Media will have instilled in them safety protocols and controls in order to avoid and prevent public hazard or catastrophe with UAS operation. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as recorded flight data and other information gained through permitted flight operations will be shared with the FAA through any required FAA reports to assist with future protocol and safety regulations.

Granting All A Dream Media’s request comports w ith the Secretary of Transportation’s responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” u nder Section 333(c) of the Reform Act specificto the use of UAS's for real estate purposes. Further, All A Dream Media will conduct

operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, All A Dream Media, respectfully requests the grant of an exemption allowing to operate light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the California area and to enhance real estate l isting videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of these will promote local economic growth through increased employment and increased tax base.

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 completi on 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 li ght of the following:

• The UAS’s 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).

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 §40101 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 subsection (a) or (b) of this section or any sections 44702

-44716 of this title if the Adminis trator 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).

All A Dream Media’ UASs are rotorcraft, weighting 50 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 40 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously.They will operate only in line of sight and will operate only within a predetermined and

closed off property area under the permission of the property representative. Such operations will insure that the sUAS 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 UASs 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 co mmercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant UASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 33 3 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 UASs for movie and commercial videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requeste d exemption without delay.



### 4. Ho**w Request Will Benefit the Public A s**  **A Whole:** 

Aerial videography for business use, geographical awareness and for real estate marketing has been traditionally completed with manned fixed wing aircraft and helicopte rs. Aerial videography is cost prohibitive. Only large businesses and high end Realtors or luxury homeowners can afford such expense. This deprives small businesses, non

- luxury homeowners, and small budget Realtors from a valuable marketing tool. Manned ai rcraft pose more of a threat to both the pilots and the general public due to the size and the combustible fuel held on board than do small UAS, which are low mass and contain no fuel.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system. The multicopters proposed for exemption are battery powered and creates no emissions that can harm the environment. The consequence of a small UAS crashing is far less than a full size helicopter or fixed wing aircraft.

Permitting All A Dream Media to immediately fly within national air space furthers economic growth. Granting the exemption request substantially furthers the economic impact for the California community by providing important technological advancements to be incorporated into the state’s commercial business. Utilizing UAS technologies, AllA Dream Media will help build academic community awareness to benefit/stimulate

attraction to the California area and to e nhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. This will in turn help promote economic growth through employment and tax revenues.



### 5. A **ircraft and Equivalent Level of Safety**

All A Dream Media 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 t o operations under the current regulatory structure because the proposed operations are conducted on closed off property under the permission of the property owner or property representative.

These limitations and conditions to which All A Dream Medi a agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh no more than 50 lbs including payload. 2. Flights will be operated within visual line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 15% battery power regardless of flight time. 4. The UAS will operate at a flight speed of more 100 mph, particularly because the maximum flight speed of the Phantom 3 i s 16 m/s (~36 mph) and the Inspire 1 is 22 m/s (~50 mph). 5. Flights will be operated at an altitude of no more than 400 feet above ground level. 6. Minimum crew for each operation will consist of the UAS Pilot, known as the Pilot in Command (PIC), and the Visual Observer (VO). 7. The PIC will have a minimum of 40 hours of flight time with the specified UAS equipment All A Dream Media operates. The experi ence of the PIC will be certified by All A Dream Media through background checks and, if necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). All A Dream Media will maintain flight logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records of these PICs. 8. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, vessels, or people not a ssociated with the operation or who have not signed a waiver in advance of the operation. 9. A briefing will be conducted in regard to the planned UAS operations prior to each day’s production activities. It will be mandatory that all personnel involvedwith the operational duties of the flight within the boundaries of the safety

perimeter be present for this briefing. 10. The operator will file a FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office. 11. The operator will obtain the consent of all persons involved in the filming 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. Wi th the advanced permission of the relevant FSDO, operations at closer range can be approved. 12. PIC and VO will have been trained in the operation of the specific sUAS equipment used by All A Dream Media, and recei ved up

- to

- date information on the particular UAS to be operated. 13. The PIC designated for any operation will have at least a Class 2 medical certificate. 14. Visual Observer and PIC will at all times be able to communicate by voice, radio, and/or text. 15. Written and/or oral permission from the relevant property holders or property representatives will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or o ther appropriate governmental agencies. 17. If the UAS loses communication with the PIC or loses its GPS signal, the UAS will have the capability to return to a pre

- determined location within the Security Perimeter and land autonomously. 18. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

All A Dream Media considers safety a foremost requirement with each flight. Our small unmanned aircrafts are designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss, we will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows our UASs to hover in place when radio con trols are released. W hen pilot communication is lost, the UAS is designed slowly descend to point of take off. Wewill not operate my UAS near airports, hospitals, nor police heliports, and will not operate near areas where general public is within fifty t o one hundred (50

- 100) yards depending on location, conditions and weather. Wewill be constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a man ned aircraft approach our location or we suspect manned aircraft may approach near my location. Our UASs are capable of vertical and horizontal operations, and are flown only within my line of sight of PIC, asthe remote control pilot. Utilizing battery po wer rather than combustible fuels, flights

generally last between 15

- 20 minutes, with an altitude under four hundred (400) feet.

**14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthines s Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 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 UAS. In all cases, an analysis of these criteria demonstrates that the UAS 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 witho ut the restrictions and conditions proposed.

The UASs to be operated hereunder are 50 lbs. or less fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secure d area. Unlike other civil aircraft, operations 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 opera tion as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a 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 demonstrates that there is no credible threat to nat ional security posed by the UASs due to their 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. § 45.23 (b). Marking of the A ircraft**  An exemption is needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided by having the UAS marked on its

fuselage as required by §45.29 (f) where the pilot, observer, and others working with the sUAS will see the identification of the U AS as “Experimental”. The FAA has issued the following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 10167A.

**14 C.F.R. § 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 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 no le ss than 40 hours of flight time with the specific UAS equipment All A Dream Media operates. The experience of the PIC will be certified by All A Dream Media through background checks and, if necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). All A Dream Media will maintain flight logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records of these PICs. The PIC designated for any operation will have at least a Class 2 medical certificate. The risks associated with the operation of the UAS are greatly diminished compared to the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS by a PIC meeting the standards of All A Dream Media (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

Unlike a conventional aircraft that carries the pilot and passengers, the UASs are remotely control led with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. Currently there are no pilot licenses that are specific for UAS operators, and no current FAA sanctioned pilot li cense of any type requires training with, and knowledge of, UAS equipment greater than the requirements All A Dream Media uses to certify its PICs. Therefore, the requirement of any available FAA sanctioned pilot license to operate a UAS does not make a PI C a more competent operator than one meeting the requirements of All A Dream Media. Our company hopes the FAA develops a new Pilot License specific for UAS and sUAS commercial operation, one that sets high standards on the quality of pilots and increases t he professionalism of our emerging industry. If the FAA does this, All A Dream Media's PICs will be some of the first to file for these licenses.

**14 C.F.R. § 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 for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determiningairworthiness. Given the size of the aircra ft for maintenance, and use of safety check

lists prior to each flight (summaries listed below), an equivalent level of safety will be provided. Summarized Safety Checklists:

1. Aircraft: All adjustment points will be checked for tightness; all motors and props will be inspected; all wiring will be double checked; all systems will be powered up and checked for errors. 2. Battery: Confirmation will be made that batteries are fully charged and installed/connected properly. 3. Calibration: Pre

-flight motor/gyro calibration followed by confirmation of no errors with the flight and navigation systems. 4. Transmitter: Confirm radio transmitter has sufficient charge, and is both working properly and receiving telemetry from the UAS; confirm all switches are in pre

fli ght mode. 5. Surroundings/Flight Area: Conduct one last visual inspection of the take

- off surroundings and area of airspace UAS will be operating in. Confirm all people in the surrounding areas are associated with the filming being done. 6. Take

- off Announcement : Before motors are started the PIC will announce to a designated Representative (person of authority) of the film crew that the UAS is ready to take

- off. Only after the Representative has notified all persons within the surrounding areas, and confirmed to PIC that they have clearance to lift

- off, will the motors be started and the UAS will conduct its operation. 7. Test Flight: A test flight will be conducted: after any disassembly/reassembly; after replacement of any motors or flight electronics; after any p re
-flight or in flight equipment errors that occur not resulting from environmental conditions; very first thing of any commercial operations day before filming begins; if there are any concerns about environmental conditions and potential issues with the flight path.

**14 C.F.R. § 91.9 (b) (2): Civil Ai**  **rcraft Flight Manual in the A ircraft.**  Section 91.9 (b) (2) provides that: No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manu al is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The UASs, given their size a nd configuration, have 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 PIC flying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B , 10167, 10167A, and 10602.

**14 C.F.R. § 91.103: Preflight A ction**  This regulation requires each pilot in command to take certain actions before flight to insure 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. § 91.109: Flight i nstruction:**  Section 91.109 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. UASs and remotely piloted aircraft, by their design do no t have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. 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 Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

**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 prescrib ed for helicopters by the FAA. If granted exemption, our UAS will only operate at altitudes of 400 feet AGL and less, or not more than 200 feet above an elevated platform from which filming is planned. The only exception would be in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, wherein the UAS 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 operations without their pre
- obtained consent.

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 or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will beaware of the planned flight operations. Compared to flight operations with aircraft or

rotorcraft weighing more than the maximum 50 lbs. along with 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 movie industry. In addition, the low

- altitude operations of the UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. § 91.121 A ltimeter**  **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.” Our U AS do not have a barometric altimeter, but instead a GPS altitude read out. 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. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions** The batteries powering our UASs provide no more than 30 minutes of powered flight per single charge. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would not be possible due to the reserve requirement being equal to the maximum flight time. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predet ermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 30% of battery power

— whichever happens first. Th is restriction would be more than adequate to return the UAS 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, and 10808.

**1 4 C.F.R. § 91.203 (a) & (b): Carry**  **ing Civil A ircraft Certification and Registration**  The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displa yed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 50 lbs and is 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 extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

**14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (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 i n part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applican t. Maintenance and inspections will be done in accordance with the UAS Manufacturer's Manual, and will be performed by employees of All A Dream Media following the guidelines and practices provided to us by the UAS Manufacturer. An equivalent level of safe ty will be achieved because these small UASs are very limited in size and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC 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 PIC 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.

**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 exemp tion from the following rules:14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a);

91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) an d 91.417 (a) & (b) to operate commercially a small unmanned vehicle (50 lbs or less) in commercial videography operations.

Approval of exemptions allowing commercial operations of UASs in the film industry will enhance safety by reducing risk. Conven tional film operations, using jet or piston

powered 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 nei ghborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters.) Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 50 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the film set. 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, weighing less than 50 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the

re quirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters

o perating in close proximity to the ground and people.

**Ad ditional Views and Information** 

All A Dream Media is eager to capitalize on the emerging technological advancements that UAS equipment can provide to the film, television, and real estate in dustries. It not only provides new cinematography capabilities, but also increased safety over current and past practices that used larger and more dangerous equipment. Our company wants to have the highest levels of safety and professionalism, and one thi ng essential to this is achieving a path to commercial licensing with the FAA. Webelieve this will help reduce unsafe practices, discourage improper uses, and improve public perception.

Sincerely, Shin Lee Owner, All A Dream Media