August 3, 2014

"-., _../ >. _: ; United States DepartmentofTransportation DocketManagement System 1200NewJerseyAve., SE West Building GroundFloorRoomW12-140 Washington, DC 20590
Re: Exemption Request PursuantTo Section333 ofthe FAAReformAct of2012
Dear Sir orMadam:
We are writingpursuantto the FAAModernization and ReformAct of20121 (the "Reform Act") and the procedures contained in 14 C.F.R. 11, to request that Network Media Services, LLC, d/b/a/ as Applied Drone Technologies, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so that Network Media Services, may operate its small unmanned aircraft I lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as long as such operations are conducted within and under the conditions outlined herein oras maybe establishedby the FAAasrequiredby Section 333. The conditions identified andproposedbythe applicant are drawnfrom Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate ofWaiver for MotionPicture andTelevisionFilming.
As identified and described herein, Charles Leonard, and his company Network Media Services, is an experienced, recognized veteran inthe broadcast and cable television production industry. Mr. Leonard and his previous production companies have been producing and delivering technical service applications for the broadcast industry for nearly thirty (30) years. 

### Mr. Leonard has also been an avid 

### RIC model flyer for over forty nine (49) years. Mr. Leonard has had extensive production service contracts with many entertainment multi-media conglomerates including; Disney/ABC, FOX Sports, NBC/Universal, Warner Brothers, DiscoveryNetworks, Bravo, IFC, Paramount Studios and many more. Network Media Services has been actively involved inthe technical development ofUAS/ UAV service applications to provide high definition film quality by aerial cinematography with small, unmanned aircraft and lightweight UASs. Itis currently one ofthe very few companies that is developing advanced technical applications and abilities for future commercial service applications. NetworkMedia Services has fully equippedeach ofits smallunmanned aircraftfor aerial photography and cinematography, primarily for use in the television broadcast industry, though giventheir stability and maneuverability, they may be used for other cinematography, by lawenforcementpersonnel, search andrescue andby otherfirstresponders.

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### To date, Network Media Services has rejected all offers to work with film, television, commercial television production companies and directors on locations withinthe United States, to ensure it is in compliance with any applicable F ARs. It, like other applicants, has done so despite Judge Patrick G. Geraghty's decision in the Raphael Pirkermatter and his reasoning that no FARs prohibit the use ofsmall unmanned aircraft or lightweight UASs like those flown by otherpeercompanies. Network Media Services exemption request would permit its operation of lightweight, unmanned (remotely controlled in line ofsight) UASs intightly controlled and limited airspace. Predetermined, specifically marked areas ofoperation, cordoned offlocations and corresponding enhancements to current safety controls will allow Network Media Services to operate within current safety parameters and new ones being implemented. As identified, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, safety plan or controls inplace to prevent catastrophe. NetworkMedia Services is developing a state-of-theart client website application to monitor, evaluate and implement all aerial cinematography activities with apre-flight safety and flight plan system. Granting Network Media Services request comports with the Secretary ofTransportation's (FAA Administrator's) responsibilities to not only integrate UASs into the national airspace system, butto "

...establishrequirements for the safe operationofsuch aircraft systems [UASs] in the national airspace system" under Section 333(c) ofthe Reform Act. Further, Network Media Services will conduct its operations in compliance with the protocols described herein or as otherwise establishedby the FAA. Network Media Services respectfully requests the grant of an exemption allowing it to operate lightweight, remote controlledUAS's. The Specific Sections ofTitle 14 ofthe Code ofFederal Regulations, Network Media Services Requests Exemption are: 14 CFR21; 14 C.F.R. 45.23(b); 14 CFR61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR407 (a)(1); 14 CFR 409 (a)(2); and, 14 CFR417 (a) & (b). 

### Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFRPart 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). The Extent ofReliefNetworkMedia Services Seeks andthe ReasonIt Seeks SuchRelief: Network Media Services submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 

### 331-334, seeking relief from any currently applicable FARs operating to prevent Network Media Services contemplated commercial cinematic, research and other flight

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### operations withinthe national airspace system. The ReformAct in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Network Media Services lightweight UASs meet the definition of "small unmanned aircraft" as defmed in Section 331 and therefore the integration ofNetwork Media Services lightweight UASs are expressly contemplated by the Reform Act. Network Media Services would like to operate its lightweight UASs priorto the time period by whichthe ReformActrequiresthe FAAto promulgaterules governing suchcraft. The ReformAct guides the Secretary in determining the types ofUASs that may operate safely in ournational airspace system. Considerations include:

The weight, size, speed and overall capabilities ofthe UAS; Whether the UAS will be operated near airports or populated areas; and, Whether the UAS will be operated by line of sight.

112 P.L. 95 § 

### 333 (a). Each ofthese items militates infavor ofan exemption for NetworkMedia Services. Network Media Services UASs utilizes four counter-rotating propellers for extreme balance, control and stability. They each weigh less than 55 pounds, including cinematic or other equipment. Each ofNetworkMedia Services small unmanned aircraft are designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are capable ofvertical and horizontal operations but operate only within the line ofsight ofthe remote control pilot. In addition to the remote control pilot, Network Media Services uses a spotter and a technician, such that, at minimum, three Network Media Services personnel govern the safe flight of an NetworkMedia Services aircraft atalltimes. Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. Network Media Services does not operate its UASs with less than twenty five percentbattery capacity. Safety systems inplace include a GPS mode that allowsNetworkMedia Services UASs to hover in place ifcommunication with the radio control pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. Further, Network Media Services fleet is programmed, in some instances, to slowly follow a predetermined set of waypoints to returnto a safety point if

### communications are lost. Network Media Services does not operate its UASs near airports and generally does not operate them nearpopulated areas. The UAS operating software and GPS navigation systems do not allow any ofthe Network Media Services UAS vehicles to operate near airports or restricted fly zones. The failsafe software will disable the UAS vehicles from taking offand also limit the UAS systems from operating within specific GPS preset no-fly zones. To date, Network Media Services has only operatedits fleet onprivate sets, cordoned offareas and areas underthe control

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### of Network Media Services clients. Network Media Services only operates its UASs in predetermined areas and only in compliance with well regarded safety protocols such as those contained within the well established and commonly known Motion Picture and Television Operations Manual.
NetworkMedia Services operation ofits fleet ofsmall unmanned aircraft will not "create a hazard to users ofthe national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of Network Media Services UASs, combined with their operation in cordoned off and well-controlled areas, Network Media Services fleet falls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Indeed, NetworkMedia ServicesUASs have a demonstrable safetyrecord and do notpose any threatto the generalpublic or national security. The FAA has the authority to issue the exemption to Network Media Services pursuant to the FederalAviationAct, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting Network Media Services exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing ofthe Reform Act. Second, NetworkMedia Services conducts research into safe UAS operations every time it flies one ofits UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Allowing Network Media Services to log more flight time directly relates to its research and its ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with current aerial cinematic capture methods, namely, full size helicopters. Network Media Services UASs are battery powered and create no emissions. IfanNetworkMedia Services UAS crashes there is no fuel to ignite and explode. The impact ofNetwork Media Services lightweight UASs is far less than a full size helicopter, notwithstanding the statistically noteworthy safety record offull size helicopters used in motion picture capture. The public's interest is furthered by minimizing ecological and crash impacts by permitting motion picture capture through Network Media Services lightweightUASs. Progression ofthe arts and sciences has beenfundamental to our society since its inclusion in the United States Constitution. Indeed, Congress mandated the integration ofUASs into our national airspace system, in part, to achieve progression inthis noteworthy, and inevitable, field. Permitting Network Media Services to immediately fly within the United States furthers these goals. Whether it is the amalgam of scientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel I 

### first responders that does not cost millions ofdollars, granting Network Media Services exemption request substantially furthers the public's interest inways known and currentlyunknown.

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### Reasons Why Network Media Services Exemption Will Not Adversely Affect Safety Or How The ExemptionWill Provide aLevel ofSafetyAtLeastEqual To Existing Rule: Network Media Services exemptionwill not adversely affect safety. Quite the contrary, for the reasons stated, supra, 

### permitting Network Media Services to log more flight time in FAA controlled airspace will allowNetwork Media Services to innovate and implement new and as of yet undiscovered safety protocols. In addition, Network Media Services submits the following representations ofenhancementsto currentaerial motionpicture capture techniques:

• Network Media Services UASs weigh less than 55 pounds complete with feature length motionpicture quality cameras like the Sony NEXVG 1 0;

• NetworkMedia Services only operates its UASs below400 feet;

• NetworkMedia Services UASs only operate for 5-25 minutesperflight;

• NetworkMedia Services lands its UASs whenthey reach 25% battery power;

• Network Media Services remote control pilots operate Network Media Services UASs by line ofsight;

• Network Media Services remote control pilots have video backup should they somehow lose sight ofthe UAS;

• Network Media Services staffs each flight with a remote control pilot, technician and spotterwithcommunication systems enablingreal time communicationbetweenthem;

• Network Media Services UASs have GPS flight modes whereby they hover and then slowly land if communication with the remote control pilot is lost or battery power is below25%;

• Network Media Services actively analyses electronic flight data and other sources of informationto constantly update and enhance safetyprotocols;

• Network Media Services only operates in secured areas that are strictly controlled, are away from airports andpopulated areas;

• Network Media Services conducts extensive briefmgs prior to flight, during which safety carries primary importance;

5• Network Media Services always obtains all necessary permissions and permits prior to operation; and, Network Media Services has procedures in place to abort flights in the event ofsafety breaches orpotential danger.
Network Media Services provides a level ofsafety at least equal to existing rules, and in nearly every instance, greater than existing rules. It is important to note that absent the integration ofcommercial UASs into our national airspace system, helicopters are the primary means ofaerial motionpicture capture. While the safety record ofsuchhelicopters is remarkably astounding, it is far safer to operate a battery powered lightweightUAS. First, the potential loss oflife is diminished because UASs carry no people on board and Network Media Services only operates them in specific areas away from mass populations. Second, there is no fuel onboard a UAS and thus the potential for fire orexplosions is greatly diminished. Third, the small size and extreme maneuverability ofNetwork Media Services UASs allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture amazing images, Network Media Services UASs need not be so close to the objects they are focused on. Accordingly, Network Media Services UASs have operated and will continue to operate at and above current safety levels.
A SummaryThe FAAMay Publishinthe FederalRegister:
A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals andThe Like.
14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary airworthiness certificates in relation to FAR 

### § 91.203(a)(l). The size, weight and enclosed operational area ofNetworkMedia Services UASs permits exemption from Part 21 because Network Media Services UASs meet an equivalent level ofsafety pursuant to Section 3 3 3 ofthe ReformAct. The FAA is authorized to exempt aircraft from the airworthiness certificate requirementunder boththeAct (49 U.S.C. 

### §44701 (f)) and Section 333 oftheReform Act. Bothpieces oflegislationpermitthe FAAto exemptUASs fromthe airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Network Media Services UASs meet or exceed each of the elements.
14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without anairworthiness certificate. As no such certificate will be applicable in the form contemplated by the F ARs, this Regulation is inapplicable.
14 C.F.R. 

### § 91.9 (b) (2) requires an aircraft flight manual inthe aircraft. As there are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

614 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Network Media Services UASs utilize electronic global positioning systems and internal gyroscopes to provide spatial coordination.
14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the samereasons described above. The equivalentlevel of safety will be achievedby maintaining suchcertifications andregistrations attheNetworkMedia Services flight operations center.

B. 14 C.F.R. §45.23: Marking ofTheAircraft. Applicable Codes ofFederal Regulation require aircraft to be marked according to certain specifications. Network Media Services UASs are, by defmition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft. Regardless, Network Media Services will mark its UASs in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29 (f) so that the the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.
C. 14 C.F.R. § 61.113: PrivatePilotPrivileges andLimitations: PIC.
Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. Network Media Services can achieve an equivalent level of safety as achieved by current Regulations because Network Media Services UASs do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though Network Media Services pilot vetting and training programs will. Further, private pilot licensees will operate Network Media Services UASs with the same skill. Further, the risks attendant to the operation of Network Media Services UASs is far less than the risk levels inherent inthe commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing Network Media Services to operate its UASs with a private pilot as the pilot incontrol will exceed current safety levels inrelationto 14 C.F.R. §61.113 (a) & (b).
D. 14 C.F.R. 91.119: Minimum SafeAltitudes.
14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes incertain conditions. NetworkMedia ServicesUASs will never operate at an altitude greater than 400 AGL. Network Media Services will, however, operate its UASs in cordoned offareas with security perimeters, providing a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight,

7maneuverability and speed ofNetwork Media Services UASs, an equivalent level ofsafety will be achieved.
E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.
The above-citedRegulationsrequire, amongst otherthings, aircraftowners andoperatorsto "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribedinpart43 ofthis chapter."
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Network Media Services should its requested exemptionbe granted. Network Media Services conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment of any damaged hardware. Therefore, an equivalent level of safety will be achieved. Network Media Services has researched and developedits owndesigns.

F. Summary
Network Media Services seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.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(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. 

### § 91.407 (a)(1); 14 C.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) & (b) to commercially operate its fleet ofsmall unmanned vehicles and lightweight unmanned aircraft vehicles in motion picture or television operations, to conduct its own research and to develop economicplatforms for lawenforcement 

### Ifirst responders, search andrescue. GrantingNetworkMedia Services request for exemptionwillreduce currentrisklevels and thereby enhance safety. Currently, motion picture image capture relies primarily on the use of larger aircraft running on combustible fuel. Network Media Services craft do not contain potentially explosive fuel, are smaller, lighter and more maneuverable than conventional motion picture aircraft. Further, Network Media Services operates at lower altitudes and in controlled airspace. Network Media Services has been analyzing flight data and other information in compiling novel safety protocols and the implementation of a flight operations manual that exceedscurrently acceptedmeans andmethods ofsafe flight.
There are no people onboardNetwork Media Services UASs and therefore the likelihood ofdeath or serious bodily injury is significantly limited. NetworkMedia Services operationofits UASs, weighting lessthan55 pounds andtraveling at speeds lowerthan 50 knots incordoned off areas willprovide atleastanequivalent level ofsafety asthat achievedunder currentF ARs.

8Network Media Services respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by Network Media Services pursuantto the FederalAviationAct, 85 P.L. 726 (1958), as amended (the "Act").

cc: Robert Papas Sincerely,

Charles H. Leonard, CEO NetworkMedia Services, LLC. 2646Weatherby HillsDrive SE Grand Rapids, MI 49546

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