# f;ILT

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590 3209 Latham Drive Madison, WI 53713 T 608.273.8458 F 608.273.8456

Re:Exemption Request Pursuant To Section 333 (14 C.F.R. 11) ofthe FAA Reform Act of2012

Dear Sir or Madam:

This application is being submitted on ourown behalfwithout legal council orconsulting services.

Tilt Media Inc. is afourteen year Wisconsin based S-Corporation that produces TV spots, corporate video and web videos for awide ranging clientele. We stafffive full time employees. Tilt Media Inc. is a proven leader in our community producing high definition, broadcast qualityTV spots and video for clients such as PBS, Wisconsin DNR and ThermoFisher among manyothers. Tilt Media Inc. has an award winning and experienced crew ofprofessionals who are experts at creating high definition videos in a variety ofsituations and locations.

We are writing pursuantto the FAA Modernization and Reform Act of2012 (the Reform Act) and the procedures contained in 14 C.F.R. 11, to request thatTilt Media Inc., an ownerand operatorofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) so thatTilt Media Inc. may operate its small unmanned aircraft system (sUAS) commercially in airspace regulated bythe Federal Aviation Administration (FAA). The petitionerTilt Media Inc. is also filingfor a Certificate ofWaiver orAuthorization (COA). In the eventthat aCOA request is not granted Iwould askthatthis request for exemption still be granted with a conditional use.
The aircraftthatTilt Media operates is a DJI Phantom II P330Z (US ID# NT0049970) lightweight (under 5 pounds) quadcopter with asmall GoPro camera and outfitted with an FPV (first-person view) system and updated with all the latest DJI Phantom firmware. The latestfirmware (V3.12) added a No-Fly Zone centered on the White House and extendingfor a 25 kilometer (15.5 mile) radius in all directions. This addition is part of DJI's ongoingworkwith regulators to ensure safe flight, and is being included in a scheduled firmware update. DJI is continuingto update its no fly zone listto include sensitive institu-tions and national borders in compliance with local regulations and helps users comply with the FAA:s NOTAM 0/8326. The DJI Phantom II is renowned as astable, safe and highly maneuverable sUAS and they are highly regarded by experts in the field of unmanned rotorcraft, as well as filmmakers.

Tilt Media Inc. will utilize it's sUAS forthevideo production industry, though given the DJI's stability and maneuverability, they may be used for othercinematography such as real estate, agriculture and other uses.
Tilt Media Inc.'s founder, Rich Rubasch, lead pilot (PIC) and member ofthe AMA (Academy of Model Aeronautics) and the AVUSI (Association for Unmanned Vehicle Systems International) has operated the lightweight DJI Phantom II for more than 80 flight hours without incident and would like to formally request permission to flythis sUAS commercially in the United States to capture aerial cinematography, and for clients who request surveying orfor educational uses. Rich has flown control-line and other RC aircraftforyears as a hobbyist. Rich is in good medical health and sound mental health, with no arrests orfelonies.

Tilt Media Inc.'s exemption request would permit its operation ofthe lightweight, unmanned (piloted by remote control) and comparatively inexpensive sUAS in tightly controlled, closed sets and in very limited airspace under 300 feet. All flights will occur over private or controlled access propertywith the property owner's priorconsent and knowledge. Filming will take place on sets whose owners have consented to filming orotherwise have agreed to allowfilming in the area where filming will take place. Predetermined, specifically marked areas ofoperation, cordoned off locations and corresponding enhancements to current safetycontrols will allowTilt Media Inc. to operate within current safety parameters. With ateam of3 dedicated individuals each flight is conducted with Line ofSight (LOS) and on site crew will include Pilot, Navigator and Spotter. To date, Tilt Media Inc. has flown countless flights at approved Wisconsin AMA parks and its own property and has done so safely and successfully.

The limitations and conditionsto which Tilt Media Inc. agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 5 lbs with full payload. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum total flight time for each operational flight will be <20 minutes. Flights will be terminated at 20% battery power or less. Safety features on the DJI PHANTOM II include auto "return-to-home," an integrated GPS auto-pilot system that offers position holding, altitude lock and stable hovering as well
as acomplete FPV video system to viewthe cameras eye view atthe controller on the ground.4. Pre-flight inspection would include checking battery condition/level in both the transmitter and UAS. The binding/linkfeature will not letthe UAS start ifcommunication is not established. Pre-flight checks for power lines, antennas and otheroverhead objects would be performed. Wind conditions would be monitored and be asignificant factorforflying. The video quality suffers in winds greaterthan 12 miles per hour and noflights would occur in winds greaterthan this. 5. The radio frequency ofthe DJI PHANTOM II is in 2.4 GHZ range and the FPV camera in the 5.8 GHZ range. Maximum take-offweight is less than 1200g. MaxAscent/decent speed 6 meters/sec. Maximum flightvelocity 10 meters/sec. 6. Flights will be operated at an altitude of no more than 300feet (AGL) or, not more than 200feet above an elevated platform from which filming is planned. 7. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Navigator/Camera operator. 8. The UAS will only operate within a confined 11Sterile Area." The establishment ofa**~~security** Perimeter" will be set forthe flight operations area. 9. A briefingwill be conducted in regard to the planned sUAS operations priorto each day's production activities. Itwill be mandatorythat all personnel who will be performing dutieswithin the boundaries ofthe safety perimeter be present forthis briefing. 10. The operatorwill obtain the consent ofall persons involved in the filming and ensure that onlyconsenting persons will be allowed within 100feet ofthe flight operation, and this radius may be reduced to 50 feet based upon an equivalent level ofsafety determination. 11. Pilot and observerwill have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated. 12. Observer and pilotwill at all times be able to communicate byvoice and/ortext. 13. Written and/or oral permission from the relevant property holders will be obtained. 14. All required permissions and permits will be obtained from territorial, state, county orcityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capabilityto return to a pre-determined location within the Security Perimeter and land. 16. The sUAS will have the capability to abort aflight in case of unpredicted obstacles or emergencies.

The sUAS to be operated hereunder is less than 5 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by the operator, and underthe requirements and in compliance with local public safety requirements, toprovide securityforthe area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations when required. Lastly, application ofthese criteria demonstratesthat there is no credible threatto national security posed bythe UAS, dueto its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. GrantingTilt Media Inc.'s request comports with the Secretary ofTransportations (FAA Administrators) responsibilitiesto notonly integrate UASs intothe national airspace system, butto establish requirements forthe safe operation ofsuch aircraft systems [UASs] in the national airspace system underSection 333(c) ofthe Reform Act.
Further, Tilt Media Inc. will conduct its operations in compliance with the protocols described herein or as otherwise established bythe FAA. Forthe reasons stated in our attached petition, Tilt Media Inc. respectfully requests the grant ofan exemption allowing itto operate lightweight, remote controlled UASs within the national airspace system and will work hand in hand with theAMAto develop safety guidelines in our region that can be utilized by the sUAS industryfor similar commercial uses, forthwith. We believe Tilt Media can pave the way in our area forthe safe operation ofsUAS aircraft in an ethical and safe manner and workwith our local AMA chapterto create safety programs to educate the community at large aboutthevalue and benefit ofsUAS aircraftfor avariety ofuses.
Thank you. Respectfully submitted,

# o~{l____ Richard Rubasch President 

## I Founder Tilt Media Inc. 3209 Latham Drive Madison, WI 53713 0: 608-273-8458 M: 608-334-8458
www.tiltmedia.com

Attachments:
DJI Phantom II User Manual

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### ~,...**~** ,Date: PHANTOM 2 Flight Controller Firmware Version : 

### PHANTOM 2 Product Release Notes April 27, 2015 3.14 April27, 2015 PHANTOM2 Flight Controller Firmware V3.14 released
What'snew? Major New Features No-Fly Zones have been updated to include a 1.2 km radius centered on the Imperial Palace and a l km radius centered on the Prime Minister's Official Residence, both in Tokyo, Japan.

Date: PHANTOM 2 Flight Controller Firmware Version: March 3, 2015 3.12
March 3, 2015 PHANTOM2 Flight Controller Firmware V3.12 released
What'snew? Major New Features 1. No-Fly Zones have been updated to include a 25km radius centered in Washington, DC. 2. The compass calibration program has been optimized to improve reliability. 3. When automatic landing is initiated, users can now continue to control the aircraft's position and altitude. During this process, the maximum speed of ascent is l m/s. 4. Afteran automatic landing has been completed andthe motors have stopped spinning,userscan immediately restart the motors and begin a newflight. Special Note 1. It is recommended that the compass be calibrated in an environment that is free from sources of potential interference. Ifyou become aware of any source ofpotential interference, move to a different location and calibrate the compass again. Be aware that underground metal pipes may cause interference when the aircraft is close to the ground during compass calibration.

Date: PHANTOM 2 Flight Controller Firmware Version: PHANTOM 2 Assistant Version: January30,2015 3.10* 3.8 January 30, 2015 PHANTOM2 Flight Controller Firmware V3.10 released*
*The flight controllerfirmware v3.10 has been discontinued. Its updateshave been optimized and included in the v3.12 update.

©2013-2015 DJI. All Rights Reserved.

### PHANTOM 2 Product Release Notes What's new?
Major New Features 1. No-Fly Zones have been updated to include a 25km radius centered in Washington, DC. 2. "Upgrade All" function added to the DJI Phantom Assistant. 3. When automatic landing is initiated, users can now continue to control the aircraft's position and altitude. During this process,the maximum speed ofascent is 1m/s. 4. Afteran automatic landing has been completed andthe motorshave stopped spinning, userscan immediately restart the motors and begin a newflight.

©2013-2015 DJI. All Rights Reserved. 2REGISTRATION NOT TRANSFERABLE UNITED STATES OF AMERICA 

# IThis certificate DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRATION must be in the airCERTIFICATE OF AIRCRAFT REGISTRATION craft when operated. NATIONALITY AND 

# 1
AIRCRAFT SERIAL NO. REGISTRATION MARKSN 558CR PH645221701 MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT Djl PHANTOM 2 P330Z ICAO Aircraft Address Code: 51616545 This certificate is TILT MEDIA INC issued for I registration purposes 

### s 3209 LATHAM DR only and is not a 

### s MADISON WI 53713-4615 certificate oftitle. u The Federal Aviation E Administration does D not determine rights ofownership as T between private 0 persons. Corporation 

# 0 It is certified that the above described aircraft has been entered on the register ofthe Federal Aviation Administration, United States ofAmerica, in accordance with the Convention on International Civil Aviation dated December 7, 1944, and with Title 49, United States Code, U.S. Department and regulations issued thereunder. DATE OF ISSUE june 2, 2015

### ~~~&~/**t:::~:r-;:: .~** **··~~P!;J~Iio~---·** .. ·· · · =Pivtii'tiow'- '· EXPIRATION DATE june 30, 201 8 ADMINISTRATOR Administration AC Form 8050-3 (1 0/201 0) Supersedes previous editions 

### u.s. Department ofTransportation Federal Aviation Administration Civil Aviation Registry. P.O. Box 25504 Oklahoma City, OK 73125-0504 Official Business Penalty for Private Use $300 AC Form 8050-3 (10/2010) Supersedes previous edition 

### TQ: TILT MEDIA INC 3209 LATHAM DR MADISON WI 53713-4615 558CR