Sept 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Found Industries LLC for an Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 

Director: Flight Standards Service:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform

Act") and 14 C.F.R. Part 11, Found Industries LLC ("Found Industries") hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") identified below to allow 

commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or 

"UAS") for the purpose of conducting: closed-set filmmaking cinematography for film, 

television and music industry as well as aerial photography for print media.

This petition for exemption is made based on information outlined in this Petition for Exemption, 

as well as the accompanying Found Industries documents;

1. PIC Flight Operations Manual and;

2. Operations Manuals 

(collectively referred to as "Found Industries' Documents & Manuals")

3. User Guide and;

4. Flight Manual1 

(collectively 3 and 4 are referred to as "Manufacturer's Manuals").

Found Industries submits these supporting materials as confidential documents pursuant to 14

C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary 

information that Found Industries has not and will not share with other requesting parties. 

Additionally, these documents contain operating conditions and procedures that are not generally 

available to the public and are protected from release under the Freedom of Information Act, 5 

U.S.C. § 552 et. seq.

 

1

. The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited 

to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service 

information letters and, safety/service bulletins.
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Page 2

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Closed-set filmmaking and cinematography 

III. Relevant Statutory Authority

IV. Found Industries’ Proposed UAS Operations Meet the Requirements of 

Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational 

Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

V1. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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I. DESCRIPTION OF PETITIONER

Found Industries LLC is an aerial photo/videography service provider, based in Ventura 

California working throughout the six counties of Southern California. Petitioner Gregory 

Constantakis is founder and CEO of Found Industries. Andrew Stai is chief pilot and post 

production manager for petitioner with more than three years experience flying UAS’s with 

multirotor platforms under 55 lbs. no less than two times a week without any compromise or 

damage to the public safety or to adjoining property. Found Industries’ staff are well trained and 

experienced in providing support as visual observers (“VO”) for the pilot in command (“PIC”) in 

addition to any other needed on site assistance.

Found Industries’ services include offering aerial video and photo services to property and 

business owners for advertising and promotional purposes, commercial art, and stock footage. 

Specifically the company provides closed-set filmmaking cinematography for the film, television 

and music industry as well as aerial photography for print media and other related media 

products.

All of the equipment owned by Found Industries is of the highest quality gear and has been able 

to provide these services safely and without any claims or incident. Found Industries’ goal is to 

advise the perspective client that Found Industries is following all the applicable state and federal 

rules to ensure the safety of the public while providing the client with a competitive and cost 

effective product.

Found Industries seeks an exemption to allow for commercial operations of small UASs to 

provide aerial photography and video services to the film, television and music industry as well 

as print media.

The contact information for Petitioner is as follows:

Greg Constantakis

Found Industries LLC

305 S Kalorama Street

Ventura California, 93001

954.242.5935: 

Greg@foundind.com

II. DESCRIPTION OF PROPOSED OPERATION

Found Industries seeks an exemption pursuant to Section 333 of the Reform Act to operate the

DJI S1000 and Cinestar 8 MK heavy Lift (under 55lbs) also known as (FI-UAS) for the proposed 

operations discussed herein below. All UAS operations will occur under tightly controlled 

conditions on private property where Found Industries has received verifiable permission to

operate from the landowner, controller or authorized representative. The proposed UAS 

operations will be conducted in accordance with the conditions and limitations of this Petition for 

Exemption and Found Industries' Operations Manuals. As detailed in Found Industries' 

Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within 

visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 
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Sept 28, 2015

Page 4

mm away from an airport reference point. Moreover, Found Industries’ Operations Manuals 

incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area 

of UAS operations, including GPS "geo-fencing" technologies.

A. Closed-set filmmaking and cinematography 

Found Industries seeks to use small UAS’s for the purpose of conducting scripted, closed-set 

filmmaking cinematography for the film, television, music web industry as well as aerial 

photography for print media. Found Industries has purposefully tailored its operations to meet 

the requirements established by the FAA in prior grants of exemption authorizing commercial 

use of UAS in the motion picture and television filmmaking industry, including:

 Astraeus Aerial (Exemption No. 11062)

 Aerial MOB, LLC (Exemption No. 11066)

 Pictorvision, Inc. (Exemption No. 11067)

 HeliVideo Productions, LLC (Exemption No. 11065)

 Snaproll Media, LLC (Exemption No. 11063)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying-Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

All UAS filmmaking operations will occur on private property in a controlled area away from 

spectators and persons not involved in the filmmaking process. In addition, the filming will be 

conducted between dawn and dusk to ensure maximum safety for the public and those involved 

in the manipulation and operation of the UAS; VFR conditions, at altitudes below 400' above 

ground level (“AGL”). 

As set forth below, Found Industries’ operations provide an equivalent level of safety that is 

superior to performing the same work using conventional fixed-wing aircraft or helicopters.

Small UAS filmmaking operations is also safer than traditional manned aircraft performing the 

same function. Conventional operations using rotorcraft and fixed-wing aircraft in low level 

operations present risks associated with vehicles weighing tens of thousands of pounds 

(including payload) and carrying large amounts of fuel which inherently presents significant fire 

hazards as well as exposure to other chemical contaminates. It is important to note the use of 

small UAS in this area will not only be safer and more cost effective to the perspective user or 

purchaser of the service, but the quality and expanse of acquired information will be far robust 

given the low cost associated with its acquisition and provide other and provide other potential 

consumers an inexpensive. Small UAS filming is more reliable, and allows for the collection, 

dissemination, and storage of visual and other sensory data with greater precision and duration. 

Small UASs will also be capable of accessing and inspecting areas that would otherwise be 

inaccessible using conventional aircraft or other inspection methods.
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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the

FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so 

based on the following considerations:

● 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 the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and

§§ 44702 – 44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 

(petitions for exemption).

IV. FOUND INDUSTRIES’ PROPOSED UAS OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The small UAS operations proposed by Found Industries in this Petition for Exemption qualify 

for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria 

and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UASs due to their size 

weight, speed, and operational capability.

 Both the UAS have been approved for use in prior Section 333 Grants of

Exemption from the FAA.2

 The UASs weigh less than 55 pounds, including payload.

 The UASs will not be flown at a ground speed in excess of 50 knots.

 

2See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant

of Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to LowCountryRC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant of Exemption to Helinet 

Aviation Services (Exemption No. 11160); Grant of Exemption to Total Safety U.S., Inc. (Exemption No. 11156).
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 Altitude information will be generated by equipment onboard the UAS as 

specified using GPS triangulation, digitally encoded barometric altimeter, radio 

altimeter, or any combination thereof. This information will be transmitted to the pilot 

via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure 

the overall safety and predictability of the system. If connection to the remote control 

or ground control station is lost, failsafe systems will permit the UASs to return to a 

predetermined location and safely land without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the 

Federal Communications Commission ("FCC") and other appropriate government 

oversight agency requirements. The operating frequency for the FI-UAS is 2.4 GHz 

frequency bands.

If the same operations were conducted using a helicopter, the aircraft's take-off weight would 

likely exceed 6,000 pounds depending on payload. The difference in weight between the FI-UAS

and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or property in the event of an accident or incident. In addition, the 

risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in

Found Industries’ Operations Manuals

Found Industries’ Operations Manuals and the Manufacturer's Manual for the selected UASs will 

contain all the procedures and limitations necessary to safely and successfully perform the 

operations specified in this Petition for Exemption. To assist the FAA in making a safety 

assessment of Found Industries’ proposed operations, below is a summary of operational 

limitations and conditions that Found Industries will adhere to, and which will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UASs weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with 

verifiable permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be obtained for each 

flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the UAS, and one or more Visual Observers ("Observer") as 

necessary to safely conduct the mission.
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5. PICs shall possess at least a Sport Pilot's Certificate and current Class III Medical 

Certificate and/or a valid driver’s license issued in the country of the United States.

The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate.

6. The FI-UAS shall be operated within VLOS of the PIC and Observer at all times. The 

PIC must use human vision unaided by any device other than corrective lenses, as 

specified on the PIC's FAA-issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate 

verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to 

the Found Industries’ Operations Manuals. The Operations Manuals will be 

maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in the Grant of Exemption and Found 

Industries’ Operations Manuals, the conditions and limitations in the Grant of 

Exemption shall take precedence and must be followed. Otherwise, Found Industries 

shall follow the procedures outlined in their Operations Manuals.

10. Found Industries may update or revise its Operations Manuals. Revisions will be 

tracked and a revised copy of the Manual will be provided to the Administrator upon 

request. Found Industries will also present an updated and revised Operations 

Manuals if it petitions for extension or amendment to its Grant of Exemption. If an 

update or revision would affect the basis upon which the FAA grants the exemption, 

Found Industries will seek an amendment to its Grant of Exemption. Found Industries 

will contact the FAA’s UAS Integration Office (AFS-80) if questions arise regarding 

updates or revisions to the operating documents.

11. Found Industries Operations Manuals and its Grant of Exemption will be available to 

the PIC at the ground control station anytime the F1-UAS is operating.

12. The PIC is prohibited from beginning a FI-UAS flight unless (considering wind and 

forecast weather conditions) there is enough power to fly to the first intended point of 

landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the FI-UAS will be 

limited to 40 minutes or the amount of time the UAS can be flown and still maintain a 

reserve battery power of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never 

enter navigable controlled airspace without prior written authorization and approval 

from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the 
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UAS will not be operated more than 100 feet above the highest point on the structure, 

and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons. (persons other than the PIC, VO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

16. The FI-UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The FI-UAS may not operate within 5 nm of an airport reference point as denoted on 

a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with

a NOTAM as required by the Found Industries COA. The letter of agreement with 

the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the FI-UAS to confirm that it is in a 

condition safe for flight. The pre-flight inspection will account for all discrepancies, 

e.g. inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. The PIC shall not operate the FI-UAS if the 

inspection reveals a condition that affects the safe operation of the FI-UAS until the 

necessary maintenance has been performed and the FI-UAS is found to be in a 

condition for safe flight. The ground control station shall be included in the preflight 

inspection. All maintenance and alternations must be properly documented in the 

UAS records as required by Found Industries’ Operations Manuals.

19. Found Industries will carry out its maintenance, inspections, and record keeping 

requirements in accordance with the Operations Manuals. Maintenance, inspection, 

and alterations will be noted in the FI-UAS records, including total time in service, 

description of work accomplished, and the signature of the authorized person 

returning the FI-UAS to service.

20. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics (e.g., replacement of a flight critical component) 
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must undergo a functional test flight in accordance with Found Industries’ Operations 

Manuals. The PIC who conducts the functional test flight must make an entry in the 

UAS aircraft records of the flight. The requirements and procedures for a functional

test flight and UAS record entry shall be included in the Found Industries’ Operations 

Manuals.

21. The FI-UAS will be operated and maintained according to the Manufacturer's 

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the 

requirements on Found Industries’ Operations Manuals.

23. Found Industries will obtain an Air Traffic Organization ("ATO") issued Certificate of 

Waiver or Authorization, otherwise known as a COA, prior to conducting any 

operations under this Grant of Exemption. A NOTAM will be issued as required by 

the COA. All operations will be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

24. 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.

25. If the FI-UAS loses communication with the PIC, it will have the capability to return 

to a pre-determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The FI-UAS will have the capability to safely abort flight in the case of unpredicted 

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate or a valid 

state driver’s license issued within the United States.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 

25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS 

pilot with a similar UAS type platform. This requirement can be achieved by flights 

conducted and logged as a hobbyist

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of hours pursuant to 54 

CFR § 61.51(b) as UAS pilot operating the make and model of FI-UAS to be utilized 

for operations under the exemption and three take-offs and three landing in the 

preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

special visual flight rules ("SVFR") shall not be conducted.

32. The FI-UAS shall remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders, etc.).

33. FI-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are 

prohibited.

34. The FI-UAS will not be operated from an elevated platform or moving 

device/vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and 

control of the FI-UAS will comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

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, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.3

Found Industries seeks an exemption from several interrelated provisions of Title 14 of the Code 

of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the 

requested operations using a UAS. Listed below are: (1) the specific sections of 14 C.F.R for 

which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has 

established which will ensure a level of safety better than or equal to the rules from which 

exemption is sought.4

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. 

§91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

 

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to 

Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption 

would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that 

provided by the rule from which you seek exemption.
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exemption is needed. 5 If, however, the FAA determines that there are some characteristics of 

the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Found Industries’ use of the FI-UASs are safe when taking into account their size, weight, speed, 

and operational capability. As set forth in the description of proposed operations in Section 

IV(A), the FI-UAS weigh less than 55 pounds, including payload and will not be flown at a 

ground speed in excess of 50 knots. Both FI-UASs are also equipped with safety features which 

will allow Petitioner to operate the FI-UAS safely after experience certain in-flight contingencies 

or failures as noted below.

6 7

Additionally, the FI-UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive 

and operate exclusively within the parameters stated in Found Industries’ Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. Found Industries will also provide the FAA with advance 

notice of all operations via NOTAMs as required by the applicable COA. In all cases, operation 

of the FI-UAS under the proposed conditions will be at least as safe as, or safer than, 

conventional rotorcraft operating with an airworthiness certificate. Lastly, the FI-UASs do not 

need a means to communicate with other aircraft or ATC, because those capabilities will be 

 

5See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6See e.g., Grant of Exemption No. 11184 to LowCountryRC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] 

has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of global positioning

system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight 

control functionality as a backup. These safety features provide an equivalent level of safety compared to a manned 

aircraft performing a similar operation."

7See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The F1-UAS can 

be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the 

system where to go, and the system does all the flying for the operator. The F1-UAS can be operated in both semi 

and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path 

for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system 

cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in 

intelligent fault handling which allows the F1-UAS to detect a system fault while in the air and automatically fly 

back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre-set 

wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any 

point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS 

position. The flight control system employs not only GPS positioning but a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not 

exceeded. Also a flight termination link – to prevent a 'fly away' or other potentially dangerous situation – is 

available to the operator."
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possessed by the PIC and Observer, who are not onboard the FI-UAS.

8

In addition, no senseand-avoid technology is necessary for the FI-UASs because they will be operated at all times in 

VFR conditions and within VLOS of the PIC and Operator.9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that Found Industries’ small FI-UASs would otherwise 

require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness 

standards for the same reasons identified in the request for exemption from 14 C.F.R. R. Part 21, 

Subpart H, supra.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

Found Industries seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by

§ 45.23.

 

8See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

. Id
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In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft " have identification (N-Number) markings in 

accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."10

Equivalent Level of Safety

All F1-UAS flown by Found Industries will bear N-number markings that are as large as 

practicable in accordance with 14 C.F.R. Part 45, Subpart C.11

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

Found Industries seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ...have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS to be operated under this grant of exemption will not have.( Emphasis added)

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety 

or Service Bulletins. Further, as required by Found Industries’ Operations Manuals, the PIC will 

conduct a pre-flight inspection of the FI-UAS and all associated equipment to account for all 

discrepancies and/or inoperable components. Maintenance will be performed and verified to 

address any conditions potentially affecting safe operation of the FI-UAS and no flights will 

occur unless, and until, all flight critical components of the FI-UAS have been found to be 

airworthy and in a condition safe for operation. A functional test flight will be conducted 

following the replacement of any flight-critical components. As required by Found Industries’ 

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the FIUAS aircraft records of the flight.

Found Industries’ Operations Manual also includes requirements to follow the manufacturer’s 

UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit

requirements for the following applicable components: powertrain system (powerplant), 

propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, 

camera system, electrical systems (including batteries), ground control station, hazard 

accessories, and spare parts. Further, Found Industries’ Operations Manuals also include 

 

10FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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procedures to document and maintain a record of the FI-UAS’s maintenance, preventative 

maintenance, alterations, status of replacement /overhaul component parts, and the total time in 

service of the FI-UASs used under this Grant of Exemption. As a whole, the maintenance and 

inspection procedures required in Found Industries’ Operations Manuals ensure that an 

equivalent or higher level of safety will be achieved.

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Found Industries seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the FI-UASs will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant 

of Exemption to Astraeus Aerial, the FAA determined that the unique characteristics of UAS 

operation outside of controlled airspace did not warrant the addition cost and restrictions 

attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class III Medical

Certificate.12 The fulfillment of the additional requirements for a private pilot to become 

qualified as a commercial pilot would not lead to any additional safety benefits when UAS 

operations are involved.

Equivalent Level of Safety

The restrictions Found Industries has placed on its FI-UAS operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial. Found Industries will operate on private 

property away from persons and property not involved in the operation. Found Industries will 

also obtain an ATO issued COA prior to conducting any operations under this Grant of 

Exemption. All operations will be conducted in accordance with airspace requirements in the 

ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Found Industries will further ensure safe operation by 

requiring that any PIC be thoroughly versed not only in airspace and communication issues

pertaining to all aircraft operators but also in the unique aspects of UAS flight. As set forth in

the Operations Manuals, pilots will have experience not only in UAS operations generally but 

have logged flight time in the specific make and model used for the operations before they are 

permitted to participate in commercial flights on behalf of Found Industries. The pilot 

qualification, training, and currency requirements in the Operations Manuals ensure that Found 

Industries’ pilots are competent and proficient in the UAS they are operating. Found Industries’ 

training and qualification requirements are consistent with those contained in prior FAA Section 

333 Grants of Exemption, and will provide a higher level of competency and proficiency for its 

pilots and will ensure at least an equivalent level of safety.

 

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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OPERATING PARAMETERS OF THE UAS

F.14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

nasmuch as there will be no airworthiness certificate issued for the UASs, Found Industries seeks 

an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy 

condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 

91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable.13

Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with

Section V(A), supra.

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

...

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Given the small size and configuration of the FI-UAS s, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the FI-UAS because there is simply 

no room and the FI-UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 

 

13See Id. at 13-14, 22.
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91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight 

manual, registration certificate, and other required documents from the ground control station 

from which he or she is operating the aircraft.14 As this FAA Office of Chief Counsel Opinion 

clarifies, the intent of the rule is to ensure the pilot has access to these key documents during 

flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has 

access to the documents at the ground control station from which he or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Found Industries seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Found Industries’ Operations

Manuals and the Manufacturer's Manual. The PIC will perform a series of checklists designed to 

identify any defects or inoperable components in accordance with the Found Industries’ 

Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight 

procedures. The PIC will also be required to review weather, flight requirements, battery charge, 

landing and takeoff distance, UA performance data, and contingency landing areas—before 

initiation of flight. Found Industries’ Operations Manuals and the Manufacturer's Manual will be

kept at the ground control station and will be accessible to the PIC at all times while operating 

the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

Found Industries seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent 

part that "[n]o 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 not have functional dual controls. Instead, flight 

control is accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Found Industries intends to use, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are 

aboard the UAS, and as required by the Found Industries’ Operations Manuals, all persons will 

be a safe distance away in the event that the UAS experiences any difficulties during flight 

 

14Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to 

John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.
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instruction. Moreover, as required by the Found Industries’ Operations Manuals, all flight 

training will be conducted in controlled and sterile environment. As a whole, the safety 

procedures provided for in Found Industries’ Operations Manuals ensure that the proposed UAS 

operations provide an equivalent or higher level of safety than that provided by the flight 

instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Found Industries requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c).15 Section 91.119 prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, 

or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed FI-UASs operations will normally need to occur 

below 400 feet AGL. In circumstances where the FI-UAS is used to inspect a structure whose 

height exceeds 400 feet AGL, the FI-UAS will not be operated more than 100 feet above the 

highest point on the structure, and within 50 feet horizontally of the structure. Additionally, due 

the nature of the proposed operations, the Pilot and/or Observers(s) may need to be less than 500 

feet away from the FI-UAS.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

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

these operations is far less than those that presently exist with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, and speed of the FI-UASs, as 

well the controlled location where the operations will occur. In order to avoid any risk to manned 

aircraft, flight operations will be restricted to 400 feet AGL or below, or when inspecting a U.S.

structure whose height exceeds 400 feet AGL, within 100 feet above the highest point on that 

structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the FI-UASs will be operated in a restricted area, and all 

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating 

persons, unless that person is in a position where he or she is shielded from the FI-UAS and any 

possible debris resulting from its failure. As required by the Operations Manuals, flights will be 

terminated if a nonparticipating person within 500 feet of the FI-UAS leaves a shielded position.

Further, its operations will occur at least 500 feet away from vehicles or structures unless the 

property owner/controller has granted permission and the PIC has made a safety assessment of 

 

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing 

without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS 

operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. 

See e.g., Grant of Exemption No. 11157 to Slugwear, Inc., dba Likeonatree Aerial (FAA-2014-0534 at 15).
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the risk of operating closer to those objects and, operations near the PIC or Observer will not 

present an undue hazard per § 91.119(a). Adherence to these restrictions in Found Industries’

Operations Manuals will ensure operations can be conducted without compromising safety.16

K. 14 C.F.R. § 91.121: Altimeter Settings

Found Industries seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating 

an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to

the elevation of the departure airport or barometric pressure. An exemption is required to the 

extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 

can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below17, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the 

operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude 

initiation point is established for the PIC to confirm accuracy of the onboard GPS.18

The FI-UASs that Found Industries intends to use for the proposed operations will meet all these 

operational characteristics. Moreover, as required by Found Industries’ Operations Manuals, the 

PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation. Like 

prior FAA Section 333 Grants of Exemption, the FI-UASs Found Industries intends to use, and 

the safety mitigation procedures contained in the Operations Manuals, both ensure that an 

equivalent level of safety will be achieved, and a Grant of Exemption to the requirements of § 

191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Found Industries requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151 states:

 

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "If barriers or structures are 

present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then 

the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that 

nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how 

to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the 

FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the

owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a 

safety assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard."

17If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 

feet above the highest point on the structure.

18See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
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(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, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption 

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved 

by prohibiting the PIC from beginning a FI-UAS flight unless (considering wind and forecast 

weather conditions) there was enough power to fly to the first intended point of landing and, 

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this 

conclusion, the FAA considered that the UAS batteries for the FI-UAS provide approximately 50 

minutes of powered flight (with payload) and provided battery level and battery time remaining 

in minutes and seconds to the PIC.19 The FAA also considered the fact that the FI-UAS operating

manual states: “start every flight with a fully charged battery in the aerial vehicle”, and that in 

the event that the FI-UAS should run low on power, the PIC will be alerted and can land the- FIUAS as soon as possible. Like the VDOS Grant of Exemption, Found Industries’ use of the FIUAS , combined with the requirements of Petitioner's Operations Manuals, ensure that an 

equivalent level of safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the UA unless 

(considering wind and forecast weather conditions), there was enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 25% battery power remaining. 

Found Industries will adhere to this limitation for its FI-UAS flights.

The FI-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the FI-UAS

to a ground-based-on-screen display.20 As required by Found Industries’ Operations Manuals, the 

PIC will promptly fly the FI-UAS back to the home launch location or pre-determined abort 

location where it may safely land, while still maintaining a minimum of 25% reserve battery 

power. Found Industries submits that the procedures requiring flights to be safely terminated 

once the batteries fall below 25% capacity, combined with the requirement that flights only be 

conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within 

 

19Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20The FOUND-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS.
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VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent 

or higher level of safety to the public to that provided by the regulations from which exemption 

is sought.

VI. DRUG AND ALCOHOL PROGRAM

Found Industries will have policies in place to ensure that no person may participate in FI-UAS

flight operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting Found Industries’ Petition for Exemption.

Congress has established a national policy that favors early integration of UAS into the NAS in 

controlled, safe working environments such as those proposed in this Petition. Granting this

Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the

Reform Act—the FAA Administrator's assessment of whether certain UAS may operate safely in

the NAS before completion of the statutorily required rulemaking.

The proposed FI-UAS operations in this Petition for Exemption significantly improves the safety 

and reduces risk of harm, physical injury and property damage to the public at large, the property 

owners from whom permission was granted for use by Petitioner and abutting properties, staff of 

Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those 

who may be in the local vicinity. Traditional methods of inspecting and monitoring potential 

filming locations and relevant sites and facilities requires location personnel to climb towers, 

venture onto precarious roofs and other dangerous scenarios, perform elevated work for which 

the individual is neither trained nor equipped to perform, which exposes them to risk of serious 

physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors 

are often exposed to hazardous conditions, unsafe environments, culturally tense situations and 

other hazards associated with identifying specific locations for potential recording sites. The use 

of small UASs can eliminate these hazards and is ultimately a much safer method of performing 

these types of inspections.

The use of small UASs also enhances safety and reduces risk to the surrounding public because, 

unlike manned aircraft weighing thousands of pounds, carrying crew in addition to flammable 

fuel, the UASs carry no passengers or crew. Furthermore, in the unlikely event of an accident, 

Found Industries’ small battery powered FI-UAS s presents significantly less danger to 

persons on the ground when compared to operations by conventional manned aircraft.21 

 

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned 

helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will 

weigh less than 55 pounds with no onboard pilot or crew. {continued on next page}

The pilot and crew will be remotely located from the aircraft. The limited weight significantly 

reduces the potential for harm to participating and nonparticipating individuals or property in the 

event of an incident or accident. Additionally, there is a high risk to onboard pilot and crew 

during an incident or accident is eliminated with the use of a UAS for the aerial filming 

operation."
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Page 21

As Petitioner's FI-UAS’s s are battery powered, the public will also benefit from a reduction in 

harmful petroleum emissions associated with conventional aircraft performing in the same 

functions proposed herein. Lastly, as recognized by the FAA in prior Section 333 Grants of 

Exemption to filmmakers, UASs provide an additional tool for the aerial filming industry, adding 

a greater degree of flexibility, which supplements the current capabilities offered by manned 

aircraft.22 

The quality of the finished product is enhanced and provides a greater demand which will aid the 

current UAS industry and provide additional jobs as the cost of providing the needed product is 

greatly reduced. The demand for the current industrial product is increasing; therefore, given the 

lower cost, producers and others in the relevant industry will be more inclined to utilize the 

services of commercial UAS and licensed PIC’s.

VIII. PRIVACY

All Found Industries FI-UAS operations will be conducted in accordance with applicable federal, 

state, and local laws regarding privacy. All operations shall be conducted over private or 

controlled-access property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

IX. FEDERAL REGISTER SUMMARY

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: Petitioner seeks an 

exemption from the following rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c);

91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general 

public, property owners and city structures from the substantial hazards associated with 

performing equivalent film work and aerial video production with conventional

fixed-wing aircraft, rotorcraft, or other methods.

{From previous page}

X. CONCLUSION

Found Industries’ Petition for Exemption satisfies the criteria articulated in Section 333 of the

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and 

populated areas, operation within VLOS and national security. The proposed FI-UAS operations

will benefit the public as a whole by improving safety and reducing risk by alleviating human 

 

22See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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exposure to danger while lowering the attendant related costs. In consideration of the foregoing, 

this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing Found Industries to use small FI-UAS for: closed-set filming 

for the motion picture and television video production.

(The following attached items contain proprietary and commercial information exempt from 

disclosure under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a

separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

0. MPTOM Motion Picture and Television Operations Manual

1. General Operations Manual

2. PIC Operating Manual

3. Showcase Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals