Brian Crozier 

UAS Integration Office 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Filed with www.regulations.gov 

June 11 , 2015 

AkinGump 

STRAUSS HAUER & FELD LLP 

GREGORY S. WALDEN 

+1 202.887.4213/fax: +1 202.887.4288 

gswalden@akingump.com 

Re: Re: Docket FAA 2014-0400, Petition for Amendment to Exemption No. 11150A; 

Request for Expedited Handling for July 4, 2015 event 

Dear Mr. Crozier: 

This firm represents AeroCine, LLC, which received FAA Exemption No. 11150 on January 23, 

2015 authorizing AeroCine under section 333 of the 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 

Exemption No. 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 petition dated March 9, 2015. 

In this present petition for an amendment to Exemption No. 11150A, AeroCine seeks to operate 

three additional types of UASs for the purposes listed above: (1) the DJI Phantom 3 and (2) the 

DJI Inspire 1; and (3) the Aerobo X 12, 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 

exemption reflect this new corporate name. 

AeroCine also respectfully requests the FAA expedite its consideration of this petition to permit 

AeroCine to operate its UASs in the New York City area over water to cover the July 4 fireworks 

event. The particulars of this request are detailed below. 

RobertS. Strauss Building 11333 New Hampshire Avenue, N.W. I Washington , D.C. 20036-1564 1202.887.4000 1 fax 202.887.4288 I akingump com 
Brian Crozier 

Federal Aviation Administration 

June 11, 2015 

Page 2 

Requested addition of other UAS types and models 

AkinGump 

STRAUSS HAUER & FELD LLP 

The airworthiness of the 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 of the Aerobo UAV were demonstrated in AeroCine's March 9, 2015 petition for a 

second amendment. The differences between the 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 

of flying heavy multi-rotors safely. Filmmakers want to use the latest cameras; as the payloads 

increase, the aircraft must to be built to safely handle 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 of up 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. 

Requested revisions to several conditions and limitations 

AeroCine seeks a revision of conditions 1, 13, 15, 25, 26, and 27 of the Conditions and 

Limitations set forth in amended Exemption No. 11150A. 

Condition 1 will need to be revised to include the DJI Phantom 3 Professional, DJI Inspire 1, and 

Aerobo X12 UASs, as requested above. 

Condition 1 will also need to be revised to reflect the weight of the Aerobo X12, which will be in 

excess of 55 pounds including payload, 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 Aviation Administration 

June 11,2015 

Page 3 

AkinGump 

STRAUSS HAUER & FELD LLP 

AeroCine seeks approval to fly with experienced UAS operators in direct control of the craft, 

while under direct supervision of, and in direct communication with an FAA-licensed private, 

recreational, or sport pilot as aVO. This increases safety of the 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's precise laser-guided navigation system to automate flight on 

closed-set film environments. This will make flight pattern predictable and repeatable therefore 

enhancing the safety of those on set. The PIC and VO will maintain VLOS on the craft at all 

times and will be able to assume full control of craft at any time if any 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 of certain 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 on top of a 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 

set during daylight hours in a preproduction scout. The UAV will be well lit with LEDs. 

AeroCine seeks a revision to Condition 25 so that it may fly its UASs from a moving platform on 

a closed film set. AeroCine has significant experience in foreign countries operating UASs from 

moving platforms such as boats, cars, and golf carts. This is often done to help the pilot maintain 

greater visibility and directionality of the 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 of the UAS. The operation of a 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 in the 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 private 
Brian Crozier 

Federal Aviation Administration 

June 11,2015 

Page 4 

AkinGump 

STRAUSS HAUER & FELD LLP 

or controlled-access property and only with the permission of the 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 with the news gathering UAS operations. Flying a small UAV over people 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 of these vehicles would be covered 

with a soft foam-like material and contain a parachute which would deploy automatically in the 

case of loss of power, loss of altitude control if roll and/or pitch angle exceeds 35 degrees, or if 

the barometer on the vehicle stops responding. AeroCine believes this would enhance the safety 

of news gathering as a small UAV poses much less risk to persons on the ground than a 

helicopter, as the FAA recognizes. Also, the rotor wash of a UA V in comparison to a helicopter 

is minimal. 

Breaking news events inherently do not come with advance notice. The imperative to respond 

promptly would be completely negated if a Notice to Airmen were required to be issued 24 hours 

before the UAS operation. A NOT AM 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 NOT AM contemporaneously with a UAS operation when 

responding to a breaking news event. 

AeroCine will comply with all other conditions and limitations imposed in Exemption No. 

11150A. 

July 4, 2015 Fireworks Event in New York City 

AeroCine has been requested by a major television network to cover the fireworks display for the 

4th of July celebration in New 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 of this 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 

or in boats. AeroCine will also file a NOT AM for this event, ensuring the safety of operations in 

that narrow slice of airspace. 
Brian Crozier 

Federal Aviation Administration 

June 11, 2015 

Page 5 

AkinGump 

STRAUSS HAUER & FELD LLP 

The COA AeroCine will apply for will include a request to operate at night, to include additional 

UAS types, and to operate within 5 nautical miles of any NYC metro airport if any part of the 

operation will be conducted within 5 miles of any such airport, or AeroCine to will obtain a letter 

of agreement with the Port Authority of New York and New Jersey, as permitted under 

Exemption No. 11150A. 

Thank you for your consideration of this petition. 

Sincerely,