Original 10/ 2 0/2015 Page 1

October 2 0 , 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113,

14 CFR 91. 7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E ( 91.40 5, 91.407, 91.409, 91.417)

Dear Sir or Madam,

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

Act) and 14 C.F.R. Part 11, Silver Screen Tele

- Reality, Inc. ( Silver Screen ) hereby

files this petition to commercially operate DJI Phantom III Professional Unmanned

Aircraft System (UAS).

The requested exemption would support an application for a commercial Certifica te of

Authorization (COA) to u tilize the DJI Phantom III ( Phantom ) to offer Aerial

Photography and Videography services for appropriate commercial application s

. A few examples of such industries include, but not limited to, are a utomobile

dealerships, automotive industry, real estate properties, co nstruction site surveys,

structure inspections, and other potential industries that need aerial data collection.

The Phantom UAS consists of a lightweight ( 4 lb) battery operated q uadcopter

unmanned aircraft, onboard camera, and assoc iated communications equipment.

The Phantom Unmanned Aircraft (UA) has previously demonstrated to have

successfully met the safety and operational requirements resulting in previous grants of

s ection 333 exemption requests by other commercial UAS operators.

Silver Screen Tele

- Reality, Inc.

, offers marketing and videography services , specializing

in automobile dealerships. The intended operation of Phantom UAS will enhance the

services utilizing aerial p hotographs and video s for our customers.

The Phantom UA carries an onboard high resolution camera system that allows it to

perform aerial photography, and videography

.

By granting the exemption, Silver Screen ’s UAS operations will create benefits to both

the economy and the environment which are ultimately in the public interest.

The aircraft will be operated in accordance with the conditions and limitations set forth

in the grant and the following applicable restrictions:Original 10/ 2 0/2015 Page 2

- All operations will occur a t no more than 2 00' above ground level ( AGL )

- The aircraft will be operated with the permission of the property owner

- When necessary, applica ble permits will be acquired from local authorities

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC at all time

- While the aircraft is airborne, the VO will be able to co mmunicate verbally with the PIC

- When necessary and applicable, Silver Screen will file a NOTAM providing

radial/DME, radius, and a date/time group for each operation

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time

F or certain complex operations, Silver Screen may assign sensor or software

application operators to assist the operations.

We submit that the combination of ;

- Phantom UA’s lig ht weight and historically demonstrated safe operation and receiving

approval s of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operation s under the guidelines established within the grant

, t he FAA can have confidence that Silver Screen ’ s UAS operation s will have an

equivalent or greater level of safety of manned aircraft performing the same mission.

We are prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. Additional documents sup porting this petition will be

submitted following this request.

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Israel Alpert

CEO

Silver Screen Tele

- Reality, Inc.

4144 N. Central Expy,

Ste 710

Dallas, TX 75204

Tel : ( 972 ) 855

- 3500

Fax : ( 413 ) 778

- 2146

Email: oalpert@sister.tv

c c: Bryan Archer

bryan@galaxymro.comOriginal 10/ 2 0/2015 Page 3 

## TABLE OF CONTENTS

NAME, ADDRESS, AND CONTACT INFORMATION OF PETITIONER .............Page 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SILVER SCREEN

SEEKS EXEMPTION.

.............................................................................. ....................Page 4

THE EXTENT OF RELIEF SILVER SCREEN SEEKS AND THE REASON S

SILVER SCREEN SEEKS THE RELIEF

.......................................... ................ ..... Pages 4 to 6

THE REASONS WHY GRANTING SILVER SCREEN ’ S REQUEST WOULD

BE IN THE PUBLIC INTEREST ..................................................

........................... . Page 7

THE REASONS WHY GRANTING SILVER SCREEN THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY .......................................

.............................. ... Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........

. .... Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT SILVER SCREEN ’ S R EQUEST...

.............. .......... .. Page s 10 & 11

ACR ONYMS...............................................................

......... ...... Page s 11 & 12Original 10/ 2 0/2015 Page 4

NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

Israel Alpert

CEO

Silver Screen Tele

- Reality, Inc.

4144 N. Central Expy,

Ste 710

Dallas, TX 75204

Tel: (972) 855

- 3500

Fax: (413) 778

- 2146

Email: oalpert@sister.tv

cc: bryan @g alaxy mro .com

THE SPECIFIC SECTIONS OF 1 4 CFR TO BE RELIEVED FROM

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF SILVER SCREEN SEEKS AND THE REASONS SILVER

SCREEN SEEKS THE RELIEF

14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private

pilot to act as pilot in command of an aircraft in connection with any business or

employment if;

(1) flight is only incidental to that business or employment; and

(2) The aircraft does not carr y passengers or property for compensation or hire

.

Since the aircraft cannot carry passengers or property, we request to be relieved from

this regulation if our pilots at minimum,

(1) hold at least a current sport pilot certificate and,

(2) hold a dri ver license or a third class medical certificate.

By meeting conditions (1) and (2), we believe that equivalent level of safety can be

achieved by complying with 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 9 1.7 (a) states

,

“ No person may operate a civil aircraft unless it is in an airworthy condition

. ”

T his rule prohibits the operation of an aircraft without an airworthiness certificate.

Since there is no such existing certificate that is applicable for the Phantom UAS to

properly comply with the FARs, we request that Silver Screen to be relieved f rom thisOriginal 10/ 2 0/2015 Page 5

regulation.

To provide equivalent level of safety, we will ensure that the Phantom UAS is in

airworthy condition prior to every flight by following necessary safety procedures.

14 CFR 91.119 Minimum safe altitudes: Genera l

This regulation provides that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

To provide an equivalent level of safety we will only fly over private property with the

permission of the land owner. The land owner will be briefed of the expected route of

flight and the associated risks to persons and property on the ground. We maintain that

due to the small size of the Phantom , the hazard to persons, vessels, vehicles, and

structures is not comparable to manned aircraft and should be considered in granting

the exemption.

14 CFR 9 1. 121 Altimeter Settings

Th is regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft.

The Phantom aircraft will fly below 400 feet AGL and will not need to maintain

hemispherical cruising altitudes in order to de

- conflict with other aircraft.

To provide an equivalent level of safety, the PIC will check and confirm the Phantom’s

GPS altitude read out before each flight.

14 CFR 91.1 51 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

VFR conditions unless there is enough fuel to fly to the first point of intended landing

and to fly after that for at least 30 minutes. We believe the intention of this rule is to

provide a reserve of energy as a safety buffer for go

- arounds and other delays to

landing.

The Phantom UAS is battery operated and the maximum duration of flight with full

payload, from a single batte ry charge is a pproximately 23 minutes.

We believe that equivalent level of safety can be achieved by limiting our flight time to

20 minu tes with reserve energy for 3 minutes on the battery.Original 10/ 2 0/2015 Page 6

14 CFR 91 Subpart E ( 91. 405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be " approved for return to service by a

person authorized under 43.7 " after maintenance and inspection. It is our intention

that the PIC, VO or authorized personnel to perform maintenance and inspection of the

aircraft and "be authorized to approve the aircraft for return to service."

Silver Screen requests that exemptions to the regulations under conditions below;

(1) Silver Screen will follow Phantom’s manufacturer maintenance instructions

, techniques and procedures

( 2 ) To ensure equivalent level of safety, PIC will inspect the UA before each flight

looking for any structural or mechanical malfunctions

Due to the small size, light weight and simplicity of the Phantom UAS, we believe that

the equivalent safety will be achieved by permitting any of the PIC , VO or authorized

personnel, to perform maintenance

, inspection and alterations of the aircraft and " be

authorized to approve the aircraft for return to service. "Original 10/ 2 0/2015 Page 7

THE REASONS WHY GRANTING SILVER SCREEN ’ S REQUEST WOULD BE IN THE

PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR 61.113 , 61.133

14 CFR 91.9, 91.119

, 91.121

, 91.151

14 CFR 91 Subpart E ( 91 .405, 91.407, 91.409, 91.417) , is in the public’s interest and

will benefit the public as a whole for the following reasons.

1

- The Phantom III UA is battery operated and free from the harmful emissions

associated with the manned aircraft that are currently used for aerial photography

and videography.

As recently proven by several grants of section 333 petitions, UASs offer

equivalent level of safety while reducing environmental impacts, which is in the

public interest.

2

- Silver Screen ’ s UAS operation s will contribute to a po sitive aggregate

e conom ic i mpact resulting in creation of jobs both direct and indirectly.

Economic Research estimates that the UAS market will grow from $ 6 billion to

$ 82 billion over the next decade resulting in a new workforce development

. Because Silver Screen ’ s operations will create new jobs such as pilots, flight

operation staff, and administrative supporting staff, it will directly cause positive

economic impact , hence granting Silver Screen ’ s petition will benefit the public

as a whole.

3

- Congress has alrea dy proclaimed that it is in the public’s interest to integrate

Commercially flown UAS (s) into the national airspace system, hence the passing

of the FAA Modernization and Reform Act of 2012.

Granting Silver Screen ’ s petition furthers the public interest as a demonstrated

progression of integrating Unmanned Aircraft Systems into National Air Space

, thus it will benefit public as a whole

.Original 10/ 2 0/2015 Page 8

THE REASONS WHY GRANTING SILVER SCREEN THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY

Silver Screen believes that the grant of exemption from,

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of reasons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF SILVER

SCREEN SEEKS AND THE REASONS SILVER SCREEN SEEKS THE

RELIEF ” by describing how we intend to mitigate risk and accomplish FAA

equivalent and acceptable level of s afety for each 14 CFR part.

(b) As a result of Phantom unmanned aircraft’s size, weight, speed, operational

capability, proximity to airports and populated areas, operation within visual line

of sight combined with the implement ing FAA required safety procedures , we

believe that granting Silver Screen ’ s exemption request will not adversely affect

safety.

(c) DJI Phantom I II has demonstrated to satisfy necessary safety risk mitigation by

FAA thus resulting in multiple grants of section 333 peti tions.

Because of t he combination of Phantom’s proven success and the conditions

and limitations of our operations, we believe granting Silver Screen ’ s request will

not adversely affect safety.Original 10/ 2 0/2015 Page 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Silver Screen Tele

- Reality, Inc.

Petition of exemption from section s of ;

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

Silver Screen se eks FAA Regulatory exemption for commercial operati on of the

Phantom III u nmanned aircraft manufactured by DJI Co, Ltd. of China

. The Phantom unmanned aircraft system has an onboard camera system capable of

acquiring high resolution data.

Proposed operations will offer aerial photography and videography services for

appropriate commercial industries.Original 10/ 2 0/2015 Page 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT SILVER SCREEN ’ S REQUEST



### DJI Phantom I I I Unmanned Aircraft System

General Features

 Ready to Fly, Multifunctional Quad

- rotor System

 Customized H3

- 2D and H3

- 3D Gimbal Support

 Precision Flight and Stable Hovering

 25 min Flight Time & Smart Battery

 Auto Return

- to

- Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement

 Self

- tightening Propeller

 Video Downlink Support

 CAN

- Bus Expansion Module

 Control Link radio operating frequency 2.4 GHz ISM

 Operating Distance 1 mile



### Aircraft Performance

Empty Weight 2.8 lbs

Max Take

- off Weight 4 lbs

Max Flight Speed 30 Knots

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 3 m/s

Diagonal Length 350mm

Flight Time 25 min ute s



### DJI Phantom 3 Professional User Manual

Silver Screen will utilize t he DJI phantom 3’s user manual which can be found online at

the link below.

http://download.dji

innovations.com/downloa ds/phantom_3/en/Phantom_3_Professional_User_Manual_v1.

4_en_0915.pdfOriginal 10/ 2 0/2015 Page 11



### Flight Safety Resources

Silver Screen will utilize the resources provided by the organizations and their websites

at the links listed below.

FAA UAS R esources http://www.faa.gov/uas/

http://knowbeforeyoufly.org/

AMA Safety Code

http://www.modelaircraft.org/files/105.pdf



### N o Privacy Issues

Silver Screen ’ s proposed operations will create no privacy issues because the

Phantom UAS will be operating in the areas within the boundaries of the propert ies with

the land owner’s permission.

When necessary and required

, Silver Screen will also obtain any permits or

authorizations from local author ities.



## ACRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency PointOriginal 10/ 2 0/2015 Page 12

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FA Rs F ederal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management

System

FTP Flight Termination Point

FTS Flight Termination System

Crosstimbers Silver Screen Tele

- Reality, Inc.

G Hz Gigahertz

GCS G round Control Station

MHz Megahertz

MTOW M aximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

N O TA M N otice To A irman

OPA Optionally Piloted Aircraft

PIC Pilot in Command

Phantom Phantom Unmanned Aircraft System

Phantom Phantom Unmanned Aircraft

R&D Research and Development

RF Radio Frequency

RM Risk Management

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System (s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer