f;ILT 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey 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) of the FAA Reform Act of 2012 

Dear Sir or Madam: 

This application is being submitted on our own behalf without legal council or consulting services. 

Tilt Media Inc. is a fourteen year Wisconsin based S-Corporation that produces TV spots, corporate 

video and web videos for a wide ranging clientele. We staff five full time employees. Tilt Media Inc. is a 

proven leader in our community producing high definition, broadcast quality TV spots and video for 

clients such as PBS, Wisconsin DNR and ThermoFisher among many others. Tilt Media Inc. has an award 

winning and experienced crew of professionals who are experts at creating high definition videos in a 

variety of situations and locations. 

We are writing pursuant to the FAA Modernization and Reform Act of 2012 (the Reform Act) and the 

procedures contained in 14 C.F.R. 11, to request that Tilt Media Inc., an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) so that Tilt Media Inc. 

may operate its small unmanned aircraft system (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). The petitioner Tilt Media Inc. is also filing for a Certificate of Waiver 

or Authorization (COA). In the event that a COA request is not granted I would ask that this request for 

exemption still be granted with a conditional use. 

The aircraft that Tilt Media operates is a DJI Phantom II P330Z (US ID# NT0049970) lightweight (under 5 

pounds) quadcopter with a small GoPro camera and outfitted with an FPV (first-person view) system 

and updated with all the latest DJI Phantom firmware. The latest firmware (V3.12) added a No-Fly Zone 

centered on the White House and extending for a 25 kilometer (15.5 mile) radius in all directions. This 

addition is part of DJI's ongoing work with regulators to ensure safe flight, and is being included in a 

scheduled firmware update. DJI is continuing to update its no fly zone list to 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 a stable, 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 for the video production industry, though given the DJI's stability and 

maneuverability, they may be used for other cinematography such as real estate, agriculture and other 

uses. 

Tilt Media Inc.'s founder, Rich Rubasch, lead pilot (PIC) and member of the 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 fly this sUAS commercially in the United States to capture aerial cinematography, 

and for clients who request surveying or for educational uses. Rich has flown control-line and other RC 

aircraft for years as a hobbyist. Rich is in good medical health and sound mental health, with no arrests 

or felonies. 

Tilt Media Inc.'s exemption request would permit its operation of the 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 property with the 

property owner's prior consent and knowledge. Filming will take place on sets whose owners have consented to filming or otherwise have agreed to allow filming in the area where filming will take place. 

Predetermined, specifically marked areas of operation, cordoned off locations and corresponding enhancements to current safety controls will allow Tilt Media Inc. to operate within current safety parameters. With a team of 3 dedicated individuals each flight is conducted with Line of Sight (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 conditions to 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 of sight of a 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 a complete FPV video system to view the cameras eye view at the controller on the ground. 
4. Pre-flight inspection would include checking battery condition/level in both the transmitter and UAS. 

The binding/link feature will not let the UAS start if communication is not established. Pre-flight checks 

for power lines, antennas and other overhead objects would be performed. Wind conditions would be 

monitored and be a significant factor for flying. The video quality suffers in winds greater than 12 miles 

per hour and no flights would occur in winds greater than 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-off weight is less than 1200g. Max Ascent/decent speed 6 meters/sec. Maximum 

flight velocity 10 meters/sec. 

6. Flights will be operated at an altitude of no more than 300 feet (AGL) or, not more than 200 feet 

above an elevated platform from which filming is planned. 

7. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and the Navigator/Camera operator. 

8. The UAS will only operate within a confined 11Sterile Area." The establishment of a ~~security Perimeter" will be set for the flight operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production 

activities. It will be mandatory that all personnel who will be performing duties within the boundaries 

of the safety perimeter be present for this briefing. 

10. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced 

to 50 feet based upon an equivalent level of safety determination. 

11. Pilot and observer will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated. 

12. Observer and pilot will at all times be able to communicate by voice and/or text. 

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 or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land. 

16. The sUAS will have the capability to abort a flight 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 or flammable liquid fuels, and operates exclusively within a secured area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

the operator, and under the requirements and in compliance with local public safety requirements, to 
provide security for the area of operation as is now done with conventional filming. The FAA will have 

advance notice of all operations when required. Lastly, application of these criteria demonstrates that 

there is no credible threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

Granting Tilt Media Inc.'s request comports with the Secretary of Transportations (FAA Administrators) 

responsibilities to not only integrate UASs into the national airspace system, but to establish requirements for the safe operation of such aircraft systems [UASs] in the national airspace system under Section 333(c) ofthe Reform Act. 

Further, Tilt Media Inc. will conduct its operations in compliance with the protocols described herein or 

as otherwise established by the FAA. For the reasons stated in our attached petition, Tilt Media Inc. respectfully requests the grant of an exemption allowing it to operate lightweight, remote controlled 

UASs within the national airspace system and will work hand in hand with the AMAto develop safety 

guidelines in our region that can be utilized by the sUAS industry for similar commercial uses, forthwith. 

We believe Tilt Media can pave the way in our area for the safe operation of sUAS aircraft in an ethical 

and safe manner and work with our local AMA chapter to create safety programs to educate the community at large about the value and benefit of sUAS aircraft for a variety of uses. 

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 Cr:~·rn---w ·o,..re Y"\ ~) 

f'v\ a n LA o. ( s e."" t- ·c.J ; t-L d n. l ;· ""'-'2 ~,... ~ , 
Date: 

PHANTOM 2 Flight Controller Firmware Version : 

PHANTOM 2 Product Release Notes 

April 27, 2015 

3.14 

April27, 2015 PHANTOM 2 Flight Controller Firmware V3.14 released 

What's new? 

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 PHANTOM 2 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. After an automatic landing has been completed and the motors have stopped spinning, users can immediately restart 

the motors and begin a new flight. 

Special Note 

1. It is recommended that the compass be calibrated in an environment that is free from sources of potential 

interference. If you become aware of any source of potential 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: 

January 30, 2015 

3.10* 

3.8 

January 30, 2015 PHANTOM 2 Flight Controller Firmware V3.1 0 released* 

*The flight controller firmware v3.1 0 has been discontinued. Its updates have 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 of ascent is 1 m/s. 

4. After an automatic landing has been completed and the motors have stopped spinning, users can immediately restart 

the motors and begin a new flight. 

©2013-2015 DJI. All Rights Reserved. 2 
REGISTRATION NOT TRANSFERABLE 

UNITED STATES OF AMERICA I This 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 MARKS N 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 of title. 

u The Federal Aviation 

E Administration does 

D not determine rights 

of ownership as 

T between private 

0 persons. 

Corporation 0 It is certified that the above described aircraft has been entered on the register of the Federal 

Aviation Administration, United States of America, 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 

of Transportation 

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