Brian Crozier UAS Integration Office Federal AviationAdministration 800 Independence Avenue SW Washington,DC 20591 Filed with www.regulations

.gov June 11 ,2015 

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GREGORY S. WALDEN +1 202.887.4213/fax: +1 202.887.4288 gswalden@akingump

.com

Re: Re: DocketFAA2014-0400, Petition for Amendmentto ExemptionNo. 11150A; Request for ExpeditedHandling for July 4, 2015 event DearMr. Crozier: This firm represents AeroCine, LLC, which received FAA Exemption No. 11150 on January 23, 2015 authorizing AeroCine under section 333 ofthe FAA Modernization and Reform Act of 2012 to operate its unmanned aircraft system ("UAS") for purposes of capturing high definition feature film quality aerial cinematography. On April 29, 2015, AeroCine received amended ExemptionNo. 11150A to operate the same UAS- the Kopterworx Hammer X12 for additional purposes, namely real estate photography and videography, agriculture, inspections of oil and gas facilities, flare stacks, and bridge infrastructure, wildlife preservation industries, and search and rescue operations. That amended Exemption also includes authority to operate two additional types ofUASs- the DJI S1000 and the Aerobo UAV, designed and manufactured by AeroCine

- for the same purposes authorized in Exemption No. 11150, which AeroCine requested by petitiondated March9, 2015

. In this present petition for an amendment to Exemption No. 11150A, AeroCine seeks to operate three additional types ofUASs for the purposes listed above: (1) the DJI Phantom 3 and (2) the DJI Inspire 1; and (3) the Aerobo X12, and to revise several conditions and limitations set forth in Exemption No. 11150A. Also, AeroCine has been converted to a C-Corp and it is now AeroCine Ventures Inc. Accordingly, AeroCine requests that any subsequent amended exemptionreflectthis new corporate name. AeroCine also respectfully requests the FAA expedite its consideration ofthis petition to permit AeroCine to operate its UASs inthe NewYork City areaover waterto coverthe July 4 fireworks event. The particulars ofthis request are detailed below.

RobertS

. Strauss Building 1 1333 New Hampshire Avenue, N.W

. IWashington , D

.C

. 20036-1564 1202

.887.4000 1 fax 202

.887.4288 Iakingump comBrian Crozier Federal AviationAdministration June 11, 2015 Page 2 Requested addition ofotherUAS types and models 

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The airworthiness ofthe DJI Phantom 3 and DJI Inspire 1 were previously determined by the FAA in Exemption No. 11583 (Flite Video, LLC), Exemption No. 11481 (Explosives Risk Managers, LLC), and Exemption No. 11342 (Geosky3, LLC). The safety features and capabilities ofthe Aerobo UAV were demonstrated in AeroCine's March 9, 2015 petition for a second amendment. The differences betweenthe Aerobo and Aerobo X12 are the four additional motors and speed controls and bigger airframe, resulting in a total weight between 85-90 lbs., depending on the camera required for the specific film shoot. It will include the same Pixhawk flight controller, but will have a total of 12 rotors and a sturdier airframe. AeroCine has a history offlying heavy multi-rotors safely. Filmmakers want to use the latest cameras; as the payloads increase, the aircraft must to be builtto safelyhandle these payloads. AeroCine's engineers have determined that this takes heavier motors, electronics, and a stronger airframe. The criteria listed in section 333 include weight as a factor for the FAA to consider, but the FAA's authority under section 333 is not limited to 55 pounds or any other weight. AeroCine notes that FAA recently granted Yamaha an exemption to operate its UAV weighing 141 pounds with an additional payload ofup to 61 pounds. AeroCine's testing has shown that its 12-rotor UAV can safely fly the payloads required by filmmakers with the weights indicated above through finite element analysis and rigorous testing of motors and electronic speed controls as determined by its mechanical and aerospace engineers. Requestedrevisions to several conditions and limitations AeroCine seeks a revision of conditions 1, 13, 15, 25, 26, and 27 of the Conditions and Limitations setforth in amendedExemptionNo. 11150A. Condition 1will need to berevisedto include the DJI Phantom 3 Professional, DJI Inspire 1, and Aerobo X12 UASs, as requested above. Condition 1will also needto be revisedto reflectthe weight ofthe Aerobo X12, which will be in excess of55 pounds includingpayload, as requested above. AeroCine seeks a revision to Condition 13. Expertly piloting a UAS for the motion picture industry is a particular skill only a small number of people have developed. AeroCine is currently restricted to pilots with an FAA private, recreational or sport pilot license. AeroCine has found most such certificated pilots to be unqualified to fly our UASs. Their manned aircraft training and experience does not give them the requisite stick skills to precisely control the UAS.Brian Crozier Federal AviationAdministration June 11,2015 Page 3 

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AeroCine seeks approval to fly with experienced UAS operators in direct control ofthe craft, while under direct supervision of, and in direct communication with an FAA-licensed private, recreational, or sport pilot as aVO. This increases safety ofthe operation as the craft will be controlled by a skilled UAS operator instead of a newly trained UAS pilot who has a private pilot license. Having an FAA-licensed private, recreational, or sport pilot as a VO will ensure AeroCine's adherence to all rules ofNational Airspace System. AeroCine is willing to provide a standard of tracking and security clearance for its non-FAA-licensed UAS pilots, such as a TWIC Card. AeroCine will incorporate PreNav'sprecise laser-guided navigation systemto automate flight on closed-set film environments. This will make flight pattern predictable and repeatable therefore enhancing the safety ofthose on set. The PIC and VO will maintain VLOS on the craft at all times and will be able to assume full control ofcraft at any time ifany unpredicted event were to occur such as the UAV deviating from its flight path. AeroCine proposes to fly its UAVs during both day and night times on closed sets, requiring a revision of Condition 15. Nighttime filming operations, which are absolutely necessary for certain portions ofcertain films, are frequently conducted with manned helicopters or from the top of adjacent buildings. Granting this exemption will provide safer operations than using a helicopter, and will have more flexibility and range than a stationery site ontop ofa building. In addition to the PIC and VO, AeroCine will require a second VO for these operations who will use an assisted-vision device such as a set of binoculars or a monocle with night vision technology. Additionally, AeroCine PICs and VOs will familiarize themselves with the closed setduring daylighthours in apreproduction scout. The UAV will be well litwith LEDs. AeroCine seeks arevisionto Condition 25 so thatitmay fly its UASs from amovingplatformon a closed film set. AeroCine has significant experience in foreign countries operating UASs from movingplatforms such as boats, cars, and golfcarts. This is oftendone to help thepilotmaintain greater visibility and directionality ofthe aircraft over long distances. Neither the PIC nor VO will be tasked with operating the moving platform and will remain completely focused on the operation ofthe UAS. The operation ofa moving cart on a closed set, and by a person who is neither the PIC nor a VO, will eliminate the risk of collision with any person not directly involved inthe operation. AeroCine also seeks a revision to Condition 26, which limits operations over non-participating persons, and Condition 27, which confines operations over persons to the airspace above privateBrian Crozier Federal Aviation Administration June 11,2015 Page 4 

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or controlled-access property and only with the permission ofthe owner/controller or authorized representative. When covering a breaking news event for live broadcast, it will often be necessary to fly over property where access is not controlled and over people who are not directly involved withthe news gathering UAS operations. Flying a small UAV overpeople at a crime scene or breaking news event would allow for a better perspective and serve the public interest. AeroCine would confine its news gathering operations to a UAV weighing no more than 4.4 lbs such as the Phantom 3 or Aerobo Mini. Both ofthese vehicles would be covered with a soft foam-like material and contain a parachute which would deploy automatically in the case ofloss ofpower, loss ofaltitude control ifroll and/or pitch angle exceeds 35 degrees, or if the barometer onthe vehicle stops responding. AeroCinebelieves this would enhancethe safety of news gathering as a small UAV poses much less risk to persons on the ground than a helicopter, as the FAArecognizes. Also, the rotorwash ofa UAV in comparisonto ahelicopter is minimal. Breaking news events inherently do not come with advance notice. The imperative to respond promptly would be completely negated ifaNoticeto Airmen were requiredto be issued 24hours before the UAS operation. A NOTAM with 24-hour advance notice may be practical for special, scheduled events, but certainly not for breaking events. Accordingly, AeroCine requests the FAA to permit the issuance of a NOTAM contemporaneously with a UAS operation when responding to abreaking news event. AeroCine will comply with all other conditions and limitations imposed in Exemption No. 11150A. July 4, 2015 Fireworks Event inNewYork City AeroCine has beenrequested by a majortelevisionnetworkto coverthe fireworks display for the 4th ofJuly celebration inNew York City. This operation will require the FAA ATC to authorize operations above 200 feet AGL, and AeroCine will apply for a COA to obtain that authority. For purposes ofthis petition, AeroCine requests expedited approval to operate its UASs

- the particular UASs previously covered in Exemption No. 11150A and the UASs included in the present petition) at night, beginning around 9 pm Eastern time. The UAVs will operate above the fireworks display, over water, thereby ensuring that there is no risk to persons on the ground orin boats. AeroCine will also file a NOTAM for this event, ensuringthe safety ofoperations in that narrow slice ofairspace.Brian Crozier Federal Aviation Administration June 11, 2015 Page 5 

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The COAAeroCine will apply for will include a requestto operate atnight, to include additional UAS types, and to operate within 5 nautical miles ofany NYC metro airport ifany part ofthe operationwill be conducted within 5miles ofany suchairport, or AeroCine to will obtain a letter of agreement with the Port Authority of New York and New Jersey, as permitted under ExemptionNo. 11150A. Thank you for your consideration ofthis petition. Sincerely,