US Department ofTransportation Exemption Request Pursuantto Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation December 23, 2015 

### Jonathan Russell Sorli 6005 HarborSeal Ct. Waldorf, MD 20603 aviatorg3@verizon.net ATP Pilot#3501255 1st Class Medical U.S Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 Re: Exemption Request Pursuantto Section 333 ofthe FAA ReformAct and Part 11 of the Federal Aviation Regulationsfrom: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

, The exemption is in the public interest. Pursuantto the authority contained in 49 U.S.C. 106(f), 40113, and 44701.

Dear Siror Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS), 

### Jonathan Russell Sorli herebyappliesfor an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated UAS, provided such operations are conducted within and undertheconditions outlined herein or as may be established bythe FAA as required by Section 333.

nd 14C.F.R. Part 11 

### Jonathan Russell Sorli an operator of Unmanned Aircraft ystems ("UASs") for aerial Photographyforthe Outdoortelevision industry, ereby appliesfor an exemption from the Federal Aviation Regulations ("FARs") o allow commercial operation of its UAS platforms.Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in thefollowing areas: 

### 1. Real Estate 2. Aerial Videography

### I Photography 

### 3. Weddings 

### 4. Bridge Inspections I Flare Stack Inspections 

### 5. Law Enforcement

### I Fire Rescue 

### 6. Utility Inspections not to limit, Pipelines 

### I Cell Tower's 

### 7. Filmmaking IClosed Set Filming 

### 8. Cinematography

### I Photography 

### 9. Public 

### I Private Events 

### 10. Construction Sites 

### 11. Search and Rescue 

### 12. News Gathering 

### 13. Risk Management

### IAssessment 

### 14. Surface Mining 

### 15. Public and Private Awareness to improve safetyforcurrant & future UAS operations within the NAS. 

### 16. Special Events 

### 17. Disaster and Catastrophe Events. On or about Sept 25, 2014 the FAA granted exemptionsto six UAS operators, including Astraeus Aerial. As set forth in Top Shot's Flight Operations and Procedures Manual (the "FOMP") and Motion PictureTelevision Operations Manual (both submitted separately under 14 CFR 11. 35 (b), Jonathan Russell Sorli

### will Adhere to the terms ofthe Astraeus Exemption. Jonathan Russell Sorli requested exemption would permit the operation of small, unmanned UAS under controlled And "sterile" conditions in the "outdoor television filming" airspacethat is: (1) limited, (2) predetermined, (3) subjectto controlled access, and (4) provide greatersafety in connection with aircraft operations in the Outdoorfilm and television industry. As established bythe exemptions already granted bythe FAA, approval ofJonathan Russell Sorli exemption would enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to establish requirements forthe safe operation of such aircraft systems in the national airspace. Below is an example how leading film organizationsfeel about using UAS's by aerial production companies; The following is a statementfrom Neil Fried, Senior Vice President, Government and Regulatory Affairsforthe Motion Picture Association ofAmerica, Inc.,"Unmanned aerial systems (UAS) offerthe motion picture and television industry an innovative and safer option forfilming. This newtool for storytellers will allow for creative and exciting aerial shots, and isthe latest in a myriad of new technologies being used byour industryto further enhancethe viewer experience. We welcomethe FAA's leadership and supporttheir guidanceto safely authorize the useof UASsfor the motion picture and television industry." This application is submitted by: 

### Jonathan Russell Sorli 6005 HarborSeal Ct. Waldorf, MD 20603 aviatorg3@verizon.net A

TP Pilot# 3501255 1stClass Medical Regulations from which the exemption is requested : 

### Fromwhichthe exemption is requested: 14CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFA 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 14CFR 91.405 (a) 14 CFR 91.407 (a) 14CFR 91.409 (a) 14 CFR 91.417 (a)

As in Grantsof Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), and 12645toAllied Drones (see Docket No. FAA-2014-0804), There is enhanced safety achieved using an unmanned aircraft (UA) with the specifications described bythe petitioner and carrying no passengers orcrew, ratherthan a manned aircraft of significantly greater proportions, carrying crew in addition toflammablefuel, givesthe FAA good cause to find that the UAS operation enabled bythis exemption is in the public interest.

### Jonathan Russell Sarli Will operate one or moreofthe Following model UAS 

### DJIInspire 1, DJI Phantom 1 Safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grantthe requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETEY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhancethe safety of the persons and/or property using conventional aircraft. These limitations and conditionsto which the applicant agreesto adhereto when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh significantly lessthan 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no morethan 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flightswill be terminated at 25% battery power reserve or30 minutes of flight timewhichever occursfirst.

5. Flightswill be operated at an altitude of no morethan 400feet Above Ground Level (AGL) and not morethan 200feet above an elevated platform from which filming is planned.6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO).

7. The UAS pilot will be a designated Pilot in Command (PIC)

.The PIC will have logged a minimum of 20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day's flights consisting of all the days' Production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. Theflights will occur in Class G airspace no closerthan a mile radius ofthe geographic center/Airport Reference Point (ARP) of atower controlled or uncontrolled airport. 12. Flights will not be closerthan a 5 mile radius ofthe geographic center/Airport.

13. Theoperatorwill do a pre check of aircraft prior to each flight. And log each flight. 14. Theoperator will obtain verbal/written consent of all persons involved with the planned operation and ensurethat only consenting persons will be allowed within 100feet of the flight operation, and the radius may be reduced to 30feet based upon an equivalent 

### level of safety determination, as U.S. Department of Transportation required underthe FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

15. The PIC and VOwill have been trained in operation of UAS and receive upto date information forthe particular UAS to be operated.

16. The PIC and VOwill be able to communicate by voice and/or radio at all times.

17. The PIC will abide by all rules18. If the UAS losescommunications with the remote controller or loses GPS signal, the UAS will havethe capability to return to a predetermined location within a designated location and land autonomously. 19. The UAS will havethecapabilityto abort a flight in case of emergencies with an automated "Return Home and Land" function. 20. The UAS will have the capabilityto abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery.

21. Any incident, accident, orflight operation thattransgressesthe lateral or vertical boundaries ofthe operational area asdefined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported tothe National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. The operating limitations proposed Jonathan Russell Sorli providefor a higher level of safety because operationsfurther enhance safety of movie and television filming operations using conventional aircraft. As setforth in the FOPM, the limitations and conditions include: The UASs will weigh lessthan 55 pounds

Flights will be operated within lineof sight of a pilot and observer Maximum flight time for each flight will be 30 minutes orat 25% of battery power reserve whichevercomesfirst. Flights will be operated at an altitude of no morethan 400 feet AGL as indicated by onboard GPS system. Minimum crewfor each operation will consist ofthe UAS pilot, the observer. A UAS pilot will be Pilot in Command (PIC). A UAS pilot will be an FAA licensed airman with at least a private pilot's certificate and third class Medical The UAS will onlyoperate within a confined "sterile area" asdefined in the FOPM. The FOPM requires the establishment of a "Security Perimeter" for the flight operations area.A briefing will be conducted for Planned UAS operations priorto each day'sflight. All personnel Performing duties within the boundaries of the safety perimeter are required to attend. The operator will file a FAA Form 7711-1 or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office. Theoperatorwill obtain consent of all persons involved in thefilming and ensure that only Consenting persons will be allowed within 100feet oftheflight operation. The operator will submit a written Plan of Activities to the FSDO three days

. beforethe proposed shoot as required in the FOPM. The Pilot and observer must betrained in UAS operations and received current information on the particular UAS to be operated as required by3 the FOPM. The Observer and Pilot will at all times be ableto communicate byvoice. Written and/or oral permission from the relevant property holders will be obtained. All required permissions and permitswill be obtained from territorial, state, county, or cityJurisdictions, including local law enforcement, fire orother managing governmental agencies. If the UAS losescommunications or loses its GPS signal, the UAS will and does havethe capabilityto return to a pre-determined location within the Security Perimeter and land safely. The UAS will have the capability to abort a flight in case of unpredicted obstacles oremergencies. 14C.F.R. 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61. 113 (a) and (b) limit private pilotsto non-commercial operations. Because the UAS Will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of Safetyof current operations by requiring the PIC operating the aircraft to have a private pilot's license Ratherthan a commercial pilot's licenseto operate a small UAS. Unlike a conventional manned aircraft, A UAS is remotely controlled by a ground-based operator. The operational area iscontrolled and restricted, and all flights are planned and coordinated inadvance. The level of safety exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraftfor hire. The risks associated with the use of a UAS are so diminished from the level of risk associated with commercial operations contemplated by part 61 allowing UAS use by a private pilot as PIC exceeds the present level of safety sought by 14 C.F.R. 61.113 (a) ab (b). 14 C.F.R. 91.103: Prefight Action Section 91.103 requires each Pilot to preflight an aircraft beforeflight to insure the safetyofflight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft per1ormance data before each flight. 14 C.F.R. 91.119 (c): Minimum SafeAltitudes Section 91. 119 establishes safe altitudesforoperation of civil aircraft. Section 91 .119 provides, in Pertinent part, that: "Except when necessaryfortakeoff orlanding, no person mayoperate an aircraft belowthefollowing altitudes:

....... ( c ) Overotherthan congested areas. An altitude of 500feet abovethe sur1ace, except over open water orsparsely populated areas. In those cases, the aircraft may not be operated closer than 500feet to any person, vessel, orstructure." BecauseJonathan Russell Sorli requests authorityto operate at altitudes only upto 400 feet AGL, an exemption is needed to allow such operations. Except for the limited conditions stated in the FOPM, the UAS will neveroperate higherthan 400feet AGL. It will, however, be operated in a restricted areawithin a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level of safetywill be achieved given the size, weight, and speed ofthe UAS as well asthe location where it is operated. No flight will be taken without the permission of propertyowners or local officials. Because ofthe advance notice to the property ownersand participants in the filming activity, all affected individuals will be informed ofthe planned flight operations. Compared to theflight operationsfor manned aircraft and the lack offlammable fuel, any risk associated with the proposed UAS operations isfar lessthan conventional aircraft operating at orbelow 500feet AGL.In addition, the low-altitudeoperations of the UAS will ensure separation between a UAS and conventional aircraft. 14 C.F.R 91.121 Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain cruising altitude by referenceto an altimeterthat is set "

... to an elevation ofthe departure airport or an appropriate altimeter setting available before departure." As a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved bythe operator, pursuantto the FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator beforeflight. 14 C.F.R. 91.151 (a): Fuel Requirementsfor Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to flytothe first point of intended landing, and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes " The battery powering theJonathan Russell Sorli UASs provides approximately 20 minutes of powered flight. To meetthe 30-minute reserve requirement in 14 CFR 91. 151, UAS flights will be limited to approximately 1 0 minutes in length. Given the limitations on the UAS's proposed flight area and its proposed flight area and proposed operations within a predetermined location, a longertime frame forflight in daylight VFR conditions is reasonable. Furthermore, operating the UASs in a tightly controlled areawhere only people, property owners, or official representatives who have signed waivers will be allowed, lessthan 30 minutes of reserve fuel does not engenderthe type of risk that 91.151 was intended to address. The owner/operator of Jonathan Russell Sorli believes that safety can be achieved by limiting flights to end with a 25% battery reserve as indicated on the PIC's controller mounted monitor. This restriction would be more than adequateto return the UASto its predetermined landing area. 14 C.F.R. 91.405 (a) (1); 407 (a) (1); 409 (a) (2); 417 (a) and (b): Maintenance Inspections These regulations require that an aircraft operator orowner shall "havethat aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

.....," and others shall inspect or maintain the aircraft in compliance with Part 43.Given thatthese sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections. Maintenance will be accomplished bythe operator. An equivalent level of safety will be achieved becausethe UASs are limited in size, will carry a small payload and operate only in restricted areasfor limited periods oftime. If mechanical issues arise, the UAS can land immediately and will be operating from no higherthan 400feet AGL. As provided in the FOPM, theoperator will ensurethat the UAS is in working order priorto flight, perform any required maintenance, and keep a log·of any maintenance performed. Moreover, the operator isthe person mostfamiliar with the UAS and best suited to maintain it in an airworthycondition. 14 C.F.R. 91.203 (A) and (B); 91.715 Airworthiness certificates Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owneror, for operation within the United States, the second copy of theAircraft Registration Application as provided for in§47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person mayoperate a civil aircraft unlessthe airworthiness certificate ora special flight authorization issued under§ 91.715 is displayed at the cabin orcockpit entrance so that it is legibleto passengers or crew. A UAS has no certificate nordoes it have a cockpit door, Jonathan Russell Sorli is requesting an exemption from 91.203 (a) and (b) also 91.715.

Pursuantto 14C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Jonathan Russell Sorli seeks an exemption from thefollowing rules: 14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151 (a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b); 91.203 (a) and (b); 91.715 to operate commercially a small unmanned vehicle (55 pounds or less) in motion picture and television operations. As established bythe UAS exemptions alreadygranted bythe FAA, allowing commercial operations of UASs in the film industrywill enhance safety by reducing risk. Conventional film operations, using turbine aircraft, operate at low altitudes and present the risks associated with aircraftthat weigh around 4,000 pounds, and which carry large amounts ofJet A fuel. Such aircraft must also fly to and from thefilm location. In contrast, a UAS weighing fewerthan 55 pounds and powered by batteries eliminatesvirtually all of that risk given the small sizeand lack of combustible fuel. The UAS is carried, and notflown, to a film set. In this regard, the UAS carries no passengers or crew and, therefore, will not exposethem to the risks associated with manned flights. The operation of UASs conducted in thestrict conditions outlined in the FOPM will provide an equivalent level of safety supporting the grant ofthe exemption requested herein. The UASsoperate at slow speeds, close to the ground, and in a sterile environment. UAS's also havefar less impact on the environment compared to normal filming practices it replaces. As a result, they arefar safer than conventional operations conducted with turbine helicoptersflying nearthe ground and people. Privacy All flights will occurover private orcontrolled access areas with the property owner's prior consent and knowledge. Filming will be onlyof people who have given theirconsent orotherwise have agreed to be in the area where filming will take place. Satisfaction of the criteria provided in Section 333 ofthe Reform Act of 2012 (size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line of sight and national security) provide more than adequatejustification to grant Jonathan Russell Sorli requested exemption, allowing for Jonathan Russell Sorli commercial operationsforthe Outdoortelevision industry pursuant to the FOPM included herewith. If you have anyquestions orneed anyadditional information, Jonathan Russell Sorli 6005 HarborSeal Ct. Waldorf, MD 20603 aviatorg3@verizon.net Sincerelyyours,