SIMON FELDMAN STUDIO, Inc. 375 FarragutAve, Hastings-on-Hudson, NY 10706 (Office) 914-589-2423

February 12
, 2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA ReformAct and Part 11 ofthe Federal Aviation Regulationsfrom 14 C.F.R.45.23(b);14 CFR Part 21;14 CFR 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) & (b);91.405 (a); 91.407(a) (1); 91.409(a) (2);91.417 (a) & (b).
To Whom It May Concern:

Pursuant to Section 333 ofthe FAA Modernization and ReformAct of2012 and 14 C.F.R. Part 11, Simon Feldman Studio Inc., hereafter referredto as "SFS",would liketo apply for an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging and video in the Westchester NY and surrounding areas.

Public Good Aerial photography/videography for Film/Television, geographical awareness for real estate marketing and inspections has been around for a long time through manned fixed wing aircraft and helicopters. But for small business owners, its expense has been cost-prohibitive. Granting this exemption would allow the Petitioner to provide this service at a much lower cost. Further, the small UAS’s being utilized in this application will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The operation ofthe UAS’s will minimize ecological damage and promote economic growth by providing information to businesses & individuals in the Westchester and surrounding Area.

SFS has experience inflying both the DJI Phantom & DJI Inspire1 for recreational purposes aswell as the use of Flight Training software during the past 3 yearswithout incident.

SFS will abide by all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules andwill only operate in a safe environment that is strictly controlled. SFS exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) in predetermined areas away from general public, airports, heliports and vehicular traffic, under 400 feet AGL, during daylight hours and after carefully reviewing, inspecting and examining the area of aerialobservation. SFS will conduct extensive preflight inspections and protocols, during which safety carries primary importance. (see our “Flight Operations Manual” attached) This would allow for videos and photos within property boundaries for individual homeowner real estate listings.
Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAAAdministrator's) responsibilities to "

... establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) of the Reform Act.

Information Supporting this Petition as Specified in 14 C.F.R. §11.81
(a)Your name and mailing address and, ifyouwish, other contact information such as a fax number, telephone number, or e-mail address;

Simon Feldman Studio Inc. Simon Feldman, President 375 Farragut Ave Hastings-on-Hudson, NY 10706 (954) 918-3888 Email: simon@simondigital.com

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION (b) The specific section orsections of 14 C.F.R.fromwhich SFS seeks an exemption

• 21- Subpart H Certification procedures for products and parts,Airworthiness Certificates

• 45.23 - Display of marks; general

• 61.113- Private pilot privileges and limitations: Pilot in command

• 91.103- PreflightActions

• 91.105- Flight crew members at stations

• 91.109- Flight instruction; Simulated instrumentflight and certainflight tests.

• 91.119- Minimum safe altitudes: General

• 91.121-Altimeter settings

• 91.151- Fuel requirements forflights in Visual Flight Rules (VFR) conditions

• 91.203 -Civil aircraft: certification required

• 91.405- Maintenance required

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration

• 91.409 -Inspections

• 91.417 - Maintenance records (c)The extent of reliefSFS seeks, andthe reason SFS seeksthe relief SFS seeks an exemptionforseveral provisions of 14 C.F.R. Parts 21,45, 61, and 91to the extent to operate small UASs to record aerial video for cinematographic purposes.This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a)through (c) ofthe ReformAct. This law directsthe Secretary of Transportation to considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe ReformAct. In making this determination, the Secretary is required to determinewhich types of UASs do not create a hazard to
users ofthe NAS orthe public or pose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability;

• Operation ofthe UAS in close proximity to airports and populated areas; and

• Operation ofthe UASwithinvisual line ofsight ofthe operator.

ReformAct§ 333 (a). Lastly, ifthe Secretary determinesthat suchvehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system"

The FederalAviationAct expressly grants the FAA the authority to issue exemptions. This statutory authority by itsterms includes exempting civil aircraft, astheterm is defined under §40101 oftheAct, that includes sUASs,from the requirement that all civil aircraft must have a current airworthiness certificate.

TheAdministrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 of this title iftheAdministratorfinds the exemption in the public interest.49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC§44704; 14CFR§91.203 (a) (1).
14 C.F .R. 21 - Subpart H Certification procedures for products and parts, Airworthiness Certificates SFS seeks exemptionfrom 14 C.F.R.21, Subpart Hwhich statesthe certification proceduresfor products and parts aswell as airworthiness certificates. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is now donewith 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,television production and Real Estate, provide a greater degree ofsafety 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 ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, 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.SFS has developed our own training procedures and regulations in conjunction with manufactures best practices and manuals to promote and provide safe flying experiences for our PIC(s)which can be viewed in section (e) ofthis petition. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide securityforthe area ofoperation.
14 C.F.R. § 45.23 (b). Marking of the Aircraft SFS seeks exemptionfrom 14 C.F.R.45.23,which discussesthe display of marks. Specifically, section45.23 states, "(a) each operator ofan aircraft must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter (b) 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, thewords "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable".

SFSwill need exemptionfrom this regulation due to the small size ofthe aircraft and thatthere is no cabin, cockpit, or pilot stationforthe aircraft. Thewords "Experimental" has been placed on the fuselage in compliance with §45.29 (f) where the pilot, observer and othersworkingwith the sUAVwill see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A

.14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. SFS seeks exemptionfrom 14 C.F.R. 61.113,which discusses private pilot privileges and limitations for the Pilot in command (PIC).

SFS is seeking exemption from this regulation, because SFS believes that there is inconclusive evidence that a person with a private pilot certificate can successfully
maneuver a sUASwithoutfirst handflight experiencewith the particular sUAS. Infact, having a private pilot license does not automatically ensure competence at flying an sUAS in 3rd person view as required to properly operate an sUAS within the required line ofsight. However,we believe that the PIC and our FOVO (Field OperationVisual Observer) must be able to understand and correctly interact with the general aviation community. Therefore, we believe our own flight training with the sUAS will be more than satisfactory.

Our PIC (Simon Feldman) a professional Photographer/Film maker of more than 20yrs has 3 years of Hobby Model Flight experiencewith the sUAS and our FOVO (Pete Linkowski holds a current Private Pilot’s license Cert# 3374357 and Third ClassMedical Certificate. Both PIC and FOVOworktogether as aflightteamto insure proper interaction with General Aviation protocols.
14 C.F.R. 91.103- Preflight Actions SFS seeks exemptionfrom 14 C.F.R. 91.103which states that each pilot in command shall,before beginning a flight, become familiar with all available information concerning thatflight. This information must include: (a) For aflight under IFR or a flight not in the vicinity ofan airport,weather reports andforecasts,fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before starting aflight.

SFS will be operating our sUAS in VFR. Our operations manual(see attached) already includes preflight procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review of any possible flight path of general aviation, our mission flight path and weather conditions amongst other parameters required to complete the mission.

14 C.F.R. 91.105 -Flight crewmembers atstations SFS seeks exemptionfrom 14 C.F.R. 91.105,which discussesflight crewmembers at stations. Specifically, 91.105 states "(a) During takeoff and landing, and while en route, each required flight crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform duties in connectionwith the operation ofthe aircraft
or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember ofa U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if (1) The seat at the crewmember's station is not equippedwith a shoulder harness; or (2) The crewmember would be unable to perform required duties with the shoulder harnessfastened. SFSwill need exemptionfrom this regulation due to thefact that the sUASwill not have aflight crew or crew stations otherthanthe PIC and a FOVO.The PICwill also not have to be restrained into a seat via shoulder harness or safety belt at the time of the flight.
14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain flight tests SFS seeks exemptionfrom 14 C.F.R. 91.109,which discussesflight instruction, simulated instrumentflight, and certainflight tests. Specifically, 91.109 states "(a) No person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls,when (1) The instructor has determined that theflight can be conducted safely; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator andailerons, in place offixed, dual controls may be used forflight instruction to conduct a flight review required by §61.56 ofthis chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.5 7 when (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entireflight; (3) The instructor is current and qualified to serve as pilot in command ofthe airplane, meets the requirements of §61.195(b ), and has logged at least 25 hours of pilot-in-command flight time in the make and model ofairplane; and ( 4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other control seat is occupied by a safety pilotwho possesses at least a private pilot certificatewith category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side ofthe aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except inthe case of lighterthan-airaircraft,that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throw over control wheel, in place offixed, dual controls ofthe elevator and ailerons, when (i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that is being usedfor aflight testfor an airline transport pilot certificate or a class ortype rating on that certificate, orfor a part 121 proficiencyflight test, unlessthe pilot seated at the controls, otherthan the pilot being checked, isfully qualified to act as pilot in command ofthe aircraft".Again, Exceptwhen necessaryfortakeoffor landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area ofa city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstaclewithin a horizontal radius of2,000feet ofthe aircraft. (c) Over otherthan congested areas.An altitude of50Qfeet abovethe surface, except
over openwater or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500feet to any person, vessel, vehicle, or structure. (d)Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conductedwithout hazard to persons or property on the surface- (1)A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2)A powered parachute orweight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) ofthis section (a) Each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set,when operating-(1) Below 18,000feet MSL, to-(i) The current reported altimeter setting ofa station along the route andwithin 100 nautical miles ofthe aircraft; (ii) Ifthere is no stationwithin the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case of an aircraft not equipped with a radio,the elevation ofthe departure airport or an appropriate altimeter setting available before departure; or (2)At or above 18,000feet MSL,to 29.92" Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation
as shown in the following table:

SFS believes that there is inconclusive evidence that a person with a private pilot certificate or license can successfully maneuver or train someone to use an sUAS without first hand flight experience with the particular sUAS. Flying in 3rd person orientation requires built-up experience in that form offlying for many years. Therefore,
we believe our own flight training, pilot protocols and first hand experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds the requirements necessary to safely operate our sUASforthe taskswe purpose.Also, the sUASwill be operated by a remote control, which will only require a single person operator and dual controls will not be necessary.

14 C.F.R. 91.119- Minimum safe altitudes: General SFS seeks exemptionfrom 14 C.F.R. 91.119,which discusses minimum safe altitudes. As this exemption isfor a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to400AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations.As setforth herein, exceptforthe limited conditions stated in the Manual, the UASwill never operate at higher than 400AGL. Itwill 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 ofsafetywill be achieved given the size,weight, speed ofthe UAS aswell as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe 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 offlammable fuel, any risk associatedwith these operations isfar less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations and the operations of conventional aircraftthat must complywith Section 91.119.

14 C.F.R. 91.121-Altimetersettings SFS seeks exemptionfrom 14 C.F.R. 91.121,which discusses altimeter settingsfor lowest usable flight level.

C.F.R. 91121 states,Current altimeter setting Lowest usable flight level 29.92 (or higher) 180 29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210
(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent ofthe minimum altitude in feet and add the appropriate number offeet specified below, according to the current reported altimeter setting
Current altimeter setting Adjustment factor 29.92 (or higher) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000

SFS's sUAS uses both GPS altitude and barometric sensors and relays that information to our ground station. However, this data is used help the sUAS to automatically maintain position hold at the required elevation and therefore this code is not pertinentthefunctionality ofthis sUAS.
14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions SFS seeks exemptionfrom 14 C.F.R. 91.151,which discussesfuel requirementsfor flight inVFR conditions. Specifically, 91.151 states "(a) No person may begin 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, tofly afterthatfor at least 30 minutes; or (2)At night,tofly afterthatforat least45 minutes. (b) No person may begin
a flight in a rotorcraft underVFR 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, tofly afterthatfor at least 20 minutes".

SFS's sUAS has a typical mission time of less than 10 minuteswith maximumflight time of20 minutes. Since this amount less than the 30 minute reserve minimum, this
reserve minimum would not even make sense in allowing the sUAS a chance to fly. According to SFS's aircraftflight manual, the PIC is instructedto maintainflight until battery power reaches 25%, or 1st level warning. At this level, landing procedures will be intiated. Once the sUAS reads 20%, 2nd levelwarning, the flight control systemautomatically take over and initiates safe landing sequence at the logged in takeoff point. SFS policy outlined in our Flight Operations Manual achieves satisfactory safety standards.

SFS believes that an appropriate and current airworthiness certificate would not be necessary tofly a sUAS given the size ofthe aircraft and the necessary level ofskill needed to operate the aircraft. Before putting in to service, each ofour sUAS goes through our own airworthiness proceedures of miminum test flight and reliability checks.Also, our sUAS are recalibrated each at the site location before eachflight to
ensure that all systemsfunctions as designed. SFS seeks exemptionfrom this regulation because we believe this rule was not meant for a sUAS and operators.

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 SFS seeks exemptionfrom 14 C.F.R. 91.405, 91.407, 91.409, and 91.417,which discusses required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and maintenance records. In SFS's aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. SFS believes these regulations are meant for manned operated aircrafts and not unmanned systems, therefore making them unnecessary. Nevertheless,we seek an exemption from any such specific provisions to the extent FAAfinds it necessaryto grantthis request.
(d) The reasonswhy granting SFS's requestwould be in the public interest; that is, how it would benefit the public as a whole.

SFS is classified as an Film & Television Production company by the U.S. Department of Commerce and provides services to aerial support for commercial interest. SFS's
use ofa sUAS can assist in making task safer and minimize human exposure to being at dangerous elevations. SFS's sUAS usage in the aerial photography and cinematography will also reduce the time required to captured the needed scenes as compared to convention helicopters or airplanes. Ultimately, the result is quick completion oftask an reduction of dangerous elevation perspective needs.
(e) The reasonswhy granting the exemptionwould not adversely affect safety, or how the exemptionwould provide a level ofsafety at least equal to that provided by the rule from which SFS seeks exemption Our Production department will provide a level of safetythat exceedsthe level ofsafety required bythe FAAfor its use on sUAS.The following are SFS's safety procedures, features, regulations, and operating specifications for our sUAS:

• Our Squadron Leader/Chief Pilot in Charge is professional film maker of20yrs who has 3 years of RC Model building and flight experience with over 300 flight hours in Multi-Rotor 3rd person flight.

• Ourstaff includes an FAA-rated private pilotwho coordinates our FOVO integration with general aviation and continues to train as sUAS operator.

• The Pilot In Command (PIC) and Field OperationsVisual Observer (FOVO)will berequired towear hard hats, safetyvests, and safety glasses to protect the head and eyes from potential mishaps during given operational flights including training or testing of sUAS.

• Theflight area ofthe sUASwill be observedfor best take offand landing locations. Desired conditions include: flat and level surfaces clear ofdebris, at least 15ft from power lines and structures, and a minimum distance of 12ftfrom the PIC and observers.

•The sUASwill also be intheVisual Line ofSight (VLOS)to boththe PIC and FOVO during all flights.

• Flights must take place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no evening
or late nightflights.

• The PIC(s) ofthe sUASwill at least have 12 training hours or 24flights accrued before being designated working flights.

•All batteries must be charged completely before each flight and each flight must end when the battery has a 30% power level remaining.

•A visual safety inspection will occur before each flight, testing propeller tightness, security mount ofcamera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and FOVO.

• The sUASwill beflown under a height of500ftAGL.

• No PIC or FOVOwill engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so asto ensurethatthe sUAS is in a conditionforsafeflight operation and in a configuration appropriate for the purpose ofthe intended flight.

• Ifthere is morethanjust an operatorat a site during aflight,the PIC operatorand observer or FOVO will maintain two-way communication with each other during all operations; if unable to maintain two-way communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the operatorwill immediately conclude the operation.

• Ifthe communication link is lost, the sUASwill go intofail-safe mode and safely descend to its designated home-point location. Ifthe communication link is reconnected during fail-safe mode, control ofthe sUAS can be regained before landing occurs at the home-point location.

• There is nofuel or payload to the sUAS, therefore therewill be no potential explosives or risk ofexplosion ifa crash occurswith the sUAS.

• The sUASwillfeature a built in compass thatwill be recalibrated at every site to maintain accurate directional readings. The compass will also help in keeping the sUAS stable during flights. •The sUASwill record GPS location data once Ready to Fly status has been obtained.

•A minimum of6 satelliteswill activatethe Readyto Fly status. •Theweight ofthe sUAS is lessthan 15 lbs

. •The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 1.5m respectfully. With a maximumwind resistance of 18mph. •The typical aircraftwheelbasewill be less than 1OOOmm in length

. •The aircraft runs off a Li-Po battery .
(f)Asummary FAA can publish inthe FEDERAL REGISTER,stating: (1)The rulefromwhich you seek the exemption; and (2)A briefdescription ofthe nature ofthe exemption you seek

Petitioner: Simon Feldman Studio, Inc.

Sections of 14 C.F.R.Affected: 21 Subpart H;45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417
Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to Cinematographic filming subject to operating procedures that meet or exceed those that FAA requires.
(g) Any additional information, views or arguments available to support your request Please see the introduction to this exemption request.
(h) Ifyouwant to exercise the privileges ofyour exemption outside ofthe United States, the reasonwhyyou need to do so

The Operations described in this exemption request will be conducted wholly within the United States.

Attached hereto, and submitted as a confidential document, is our Flight Operations Manual. We respectfully submit that good cause exists so that this confidential manual does not need to be published in the Federal Register.

Please do not hesitate to contact me via email at simon@simondigital.com ifyou have any questions
Verytrulyyours, Simon

Simon Feldman President, Simon Feldman Studio, Inc.