llltDSHEAR MEDIA llldoo Producl•on LLC 

ltloiiOn Graphics Visual Effects 

April I 7, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Petition ofWindshear Media LLC. for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012. 

To Whom It May Concern: 

Windshear Media LLC. (WM), hereby applies for an exemption from Federal Aviation Regulations 

(FARs) identified below, to allow commercial operations of small unmanned aerial systems (i.e., 

sUAS) pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 CFR Part 

11. 

This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed 

WM's Operations Manual, the UAS manufacturer's operations and/or instructions manual, UAS 

User's Manuals, sUAS Quick Start Guides, and any other requirements established by the FAA 

pursuant to Section 333 of the Reform Act. 

Windshear Media LLC respectfully requests a waiver on the 45-day comment period, as this 

application is identical in description to other Section 333 Exemptions that have already been 

granted. 

This exemption would permit commercial operations by Windshear Media LLC, to use the Dn 

Phantom 1, on Phantom 2, DJI Inspire 1, and the DJI SlOOO, to conduct aerial photography and 

videography, agricultural assessment of crops and data collection, news gathering, training and 

education, support services for public entities, inspections and assessments of structures, real estate 

photography and videography, and closed set film and movie production. WM's operation under the 

exemption w111 be subject to specific operating requirements and conditions to ensure an equivalent 

level of safety to currently authorized operations using manned aircraft and under conditions as may 

be modified by the FAA as required by Section 333. 

Winds hear Media LLC submits the Operations Manual as a confidential document under 14 CFR § 

11.35(b ), the entire content of this manual contains confidential information that WM has not and 

will not make available to others. This manual contains operating procedures and additional 

information that is not available to the public and are protected from release under the Freedon of 

Information Act, 5 USC§ 552 (b) (4). 
WM has assembled a team ofUAS personnel, including pilots with Commercial and Instructor 

Ratings, and will be operate sUAS within the National Airspace(NAS) under controlled VFR 

conditions at or below 400' AGL. They will operate the sUAS with pilots who are current and 

qualified with a FAA Pilot Certificate and have completed WM's training program. 

Windshear Media LLC respectfully submits this request for an exemption because it operates sUAS. 

Currently, the operations ofWM will be conducting will be in lieu of comparatively hazardous 

operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have 

confidence that the operations will be conducted at an equivalent level or greater level of safety. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act 

to "establish requirements for the safe operation of such aircraft systems in the national airspace 

system." 

For your convenience, WM has organized this Exemption request as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

HI. Qualifications for Approval Under Section 333 ofthe Reform Act 

IV. Details of Proposed sUAS Operations 

V. Regulations From Which Exemption is Requested 

Vl. Public Interest 

Vll. Privacy 

VIII. Federal Registry Summary 

IX. Conclusion 

I. Petitioner's Description: 

Winds hear Media LLC, headquartered in Stevensville, Maryland, is a Production Company that also 

provides film and movie production services, support to news services, real estate photography, services to 

first responders, photographic assessment of agriculture, education, and sUAS demonstration flights in a 

compliant and safe environment. WM plans on providing a wide range of sUAS services as the market 

expands. 

The management at WM has over 45 years combined experience in aviation with both helicopter and fixedwing aircraft (including Search and Rescue, Medevac, Law Enforcement, disaster assessment, and Homeland 

Security.), and over 4 years experience operating sUAS. The Chief Pilot has over 8500 hours in both 

rotorcraft and fixed wing aircraft, has been a commercial pilot for 29 years, is a Certified Flight Instructor 

and Instrument Instructor in both Helicopter and Single Engine Land and has been an IP for 20 years. The 

Chief Pilot is intimately familiar with operational control procedures and overseeing the safe operations of an 

aviation event. The President has over 24 years working in an aviation and first responder environment as 

well as over seventeen years in video production and understands the requirements to integrate the sUAS into 

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open and closed set television and movie locations. 

WM's goal is to operate in an accident-free environment by: 

• Demonstrating a commitment by management and all employees' to operator in a compliant manner. 

• Identify hazard and risk while eliminating or controlling all these risk. They will use steps to intervene 

and report when unsafe work practices appear to exist. 

• Train all employees involved in flight operations to operate at the highest standard level. 

The contact information for Petitioner is as follows: 

Windshear Media LLC. 

Attn: Jonathan Cook 

305 Chari Court 

Stevensville, MD 21666 

Ph: 443-497-0539 

Email: Info@WindshearMedia.com 

ll. Relevant Statutory Authority: 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the 

Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National 

Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following considerations: 

• The UAS's size, weight, speed, and operational capability~ 

• Operation of the UAS in close proximity to airports and populated areas~ and 

• Operation of the UAS within the visual line of sight of the operator. 

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the 

Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace 

System". 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the pub1ic interest. A 

party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as 

a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to 

the existing rules). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from 

the requirement that all civil aircraft must have a current airvvorthiness certificate and those regulations 

requiring commercial pilots to operate aircraft in commercial service: 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any ofsections. 

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m. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of 

the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. 

The proposed operations would permit WM the use of small UAS under controlled conditions in airspace 

that is: (1) predetermined; (2) controlled as to access; and that (3) provides an Increased level of safety 

beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. 

WM uses UASs that are multi-rotor, weighing less than 55 pounds including payload. They operate, under 

normal conditions, at speeds not to exceed 50 mph. The multi-rotor has the capability to hover and move in 

the vertical and horizontal plane. WM's UAS will operate in line of sight, during daylight hours, and will 

only operate within a sterile area described in the enclosed Operations Manual. WM will operate at or below 

400 feet AGL and will file a NOT AM for each flight operated in controlled airspace that is required. All 

required permissions and permits would be obtained from territorial, state, county or city jurisdictions, 

Including local law enforcement, fire, or other appropriate governmental agencies prior to operating a 

sUAS. 

IV. Details of Proposed slJAS Operations 

The enclosed Operations Manual describes, in detail, the policies and procedures for WM's proposed sUAS 

operations. To assist the FAA in its safety assessment ofWM's proposed sUAS operations, below is a 

summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines: 

1. The sUAS w111 weigh less than 55 pounds. 

2. Flights vvill be operated within line of sight of the PIC and visual observer. 

3. Maximum total flight time for each operational flight will be limited to 20 minutes or the amount of 

time the sUAS can be flown and still maintain a reserve battery power or fuel quantity of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned. 

5. Flights will be operated at a lateral distance ofleast 100 feet from any inhabited structures, buildings, 

vehic1es, vessels, people not associated with the operation or who have not signed a waiver in advance 

of the operation. 

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual Observer. 

Additional crewmembers may consist of additional observers and a Camera Operator. 

7. The sUAS Pilot in Command will be an FAA licensed airman with a minimum of a private pilot's 

certificate and a third class medical. 

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8. WM will designate a Pilot in Command ("PIC") for each mission. 

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

activities. It will be mandatory for all personnel performing duties within the boundaries of the safety 

perimeter be present for this briefing. 

10. Prior to the operations at a particular location, a site inspection and mission briefing will have been 

conducted. On the day of the mission, the management person with operational control and the PIC will 

concur on dispatching of the mission. 

11. The PIC and Observer will remain in close enough proximity so as to be able to communicate by voice. 

12. All sUAS will be maintained in accordance with the manufacturer's guidelines. 

13. In the event of an accident involving a WM sUAS, they will cease operations and report the accident to 

the NTSB and AFS-80. 

14. Pilot in Command and Visual Observer will at all times be able to communicate by voice 

15. All PICs, VOs, and Camera Operators will be training and tested on their proficiency to operate with 

the UAS environment. 

16. All required permissions and permits would be obtained from territorial, state, county or city 

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

17. In compliance with approved Waiver, WM management will submit a written "Plan of Activities" to 

the local Flight Standards District Office (FSDO) having jurisdiction over the area of proposed filming 

three days in advanced of operations during film or movie productions. 

18. If the sUAS loses communications signal, the sUAS will have the capability to return to a predetermined location within the closed set and land. 

19. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the pilot and the observer. 

20. The sUAS has the capability to abort a flight in case ofunpredicted obstacles or emergencies. 

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V. Regulations From Which Exemption is Requested 

• 14 CFR Part 21 

• 14 CFR 45.23(b) 

• 14 CFR 61. 113 (a) & (b) 

• 14 CFR 91.7 (a) 

• 14 CFR 91.9 (b) (2) 

• 14 CFR 91. 103 

• 14 CFR 91. 109 

• 14 CFR 91.119 

• 14 CFR 91.121 

• 14 CFR 91. 151 (a) 

• 14 CFR 91.203 (a) & (b) 

• 14 CFR 91.405 (a); 407 (a) (1);409 (a) (2); 417 (a) (b) 

A. 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entttled Airworthmess Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by The Aerial Filming Company, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part II and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to atrports and populated 

areas of the particular UAS. In all cases, an analysts of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions proposed will be 

at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated is less than 55 lbs. full} loaded, carnes neither a pilot nor passenger, carries no 

explosive materials or flammable fuels, and operates exclusively v.ithin a secured area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, and 

under the requirements and in compliance with local public safety requirements. The FAA will have 

advance notice of all operations. These safety enhancements, which already apply to civil aircrail, provide a 

greater degree of safety to the public and property owners than conventional operations conducted with 

amvorthiness certificates issued under 14 C.P.R Part 21, Subpart t I. ApplicatiOn of these same cnteria 

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. 

B. 14 CFR § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station. in 

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letters not Jess than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS wtll 

have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. 

Given the size of the sUA V, two-inch lettering will be impossible. The word "Experimental" will be placed 

on the fuselage in compliance wtth §45.29 (f). 

The equivalent level of safety will be provided by having the sUA V marked on its fuselage as required by 

§45 29 (f) where the pilot, observer and others workmg with the sUA V will see the identrfication of the 

UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700,8738, 10167 and 10167A. 

C. 14 CFR §Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command 

Sections 61 113 (a) & (b) limit private pilots to non-commercial operations Because the UAS will not carry 

a pilot or passengers; the proposed operations can achieve the equivalent level of safet} of current 

operations by requiring the PIC operating the aircraft to have a private pilot's license to operate this sUAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled. The 

area of operation is controlled and restricted, and all fl1ghts are planned and coordinated in advance. The 

level of safety provided by our requirements exceeds that provided by a single individual holding a 

commercial pilofs certificate operating a conventional aircraft. The risks associated with the operation of 

the sUAS are so diminished from the level of risk associated wtth comrnerctal operations contemplated b} 

Part 61 when drafted, that allowmg operat10ns ofthe sUAS as requested with a private pilot as the PIC 

exceeds the present level of safety achieved by 14 C. F. R. §61. 113 (a) & (b). 

D. 14 CFR §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there wi11 be no airv,;orthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in our operations manual for maintenance and use of safety check lists prior to 

each flight, as set forth in Sections J, L, and Q , an equivalent level of safety ""ill be pro" ided. 

E. 14 CFR § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate aU $.-registered civil aircraft .. . 

(2) For \\hich an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

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The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capactty to carry 

such an item on the atrcraft. 

The equivalent level of safety will be maintained by keeping the fl ight manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738,9299, 9299A, 9565, 95658, 

10167, 10167A, 10602,32827,and 10700. 

F. 14 CFR § 91.103: Preflight action 

This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. An equivalent level of safety will be provided as set forth in our confidential operating manual. 

The PIC will take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

G. 14 CFR §91.109: Flight instruction 

Section 91 .103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. 

sUASs/remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control 

is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

H. 14 CFR §91.119: Minimum safe altitudes 

Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters 

to be operated at less than the mimmums prescnbed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a 

hehcopter and the exemption requests authorit) to operate at altitudes up to 400 AGL, an exemption rna} be 

needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 AGL. It 

will however be operated in an area where buildings and people will not be exposed to operations without 

their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the 

location where 1t is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the propert) owner and participants in the filming activtty, all 

affected mdividuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft \veighing far more than the maximum 551bs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS wil1 ensure 

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separation between these small- UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

I. 14 CFR §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. Our sUAS has a barometric, telemetric data feed. This altitude 

information will be generated by equipment installed on the aircraft, GPS triangulation or any 

combination thereof Before each flight, a zero altitude initiation point will be established and confirmed 

for accuracy by the PIC. 

J. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed- ( 1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the sUASs provides a maximum of approximately 40 minutes of powered flight. 

To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS 's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or night VFR conditions is reasonable. 

We believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not incur the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the 

utility for which the exemption will be granted. 

We believe that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% 

of battery power whichever happens first. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808. 

K. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as pro\lided in§ 91.715, no person may operate a civil atrcraft unless it has within it the 

following: 

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(l) An appropriate and current airworthiness certi fie ate •... 

(b) No person may operate a civil aircraft unless the ainvorthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §9 1.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

L. 14 CFR §91.405 (a);407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an atrcraft operator or owner "shall have that aircraft inspected as 

prescnbed in subpart E of this part and shalJ between required inspections, except as provided in 

paragraph (c) ofthts section, have discrepancies repaired as prescnbed in part 43 ofthis chapter .. ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an ainvorthiness certificate, these 

sections will not apply to our operations. Maintenance will be accomplished by the operator pursuant to 

the manuals and operating handbooks for each respecttve sUAS (included with the submiss10n of this 

petition). An equivalent level of safety will be achieved because these sUAS are very limited in size and 

will carry a small payload and operate only in restricted areas for limited penods of time. If mechanical 

issues arise the s UAS can land immediately and will be operating from no higher than 400 feet AGL. As 

provided in the Manual, the operator will ensure that the sUAS is in working order prior to initiating 

flight, perform reqUired mamtenance, and keep a log of any mamtenance performed. Moreover, the 

operator is the person most fami liar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety 

VI. PUBLIC INTEREST 

Granting Windshear Media LLC. an exemption furthers the public interest. National policy set by Congress 

favors early integration ofUAS into the national airspace in controlled, safe working environments such as 

those propose in this petition. Windshear Media's goal is to help facilitate safe integration of sUASs into 

mainstream USA in the following areas: 

• Videography and Photography 

• Agricultural Assessment of Crops and Data Collection 

• News Gathering 

• Training and Education 

• Support Services for Public Entities 

• Inspections and Assessments of Structures 

• Real Estate 

• Closed Set Film and Movie Production 

lD 
Vll. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding privacy. 

VITI. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: Applicant seeks an exemption from the foliO\\tng 

rules· 

14 C.F.R. §21, subpart It 14 C.F.R 45.23(b), 14 C.F.R. §§ 61.113( a) & (b),91.7 (a); 91.9 (b) 

(2);91.103(b);9l.l09; 91119; 91.121; 91.l5l(a);91.203(a) and(b); 91.405 (a); 91.407 (a)(l); 91.409 

(a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs 

or less). 

IX. CONCLUSION 

Approval of exemptions allowing commercial operatiOns of sUASs as requested will enhance safety by 

reducing risk. Conventional operations, using Jet or piston power aircraft, operate at extremely low 

altitudes and in extreme proximity to people and structures; and present the nsks associated with 

vehicles that weigh approximately 5 ,OOOlbs carrying large amounts of fuel. Such aircraft must fly to and 

from the film location. ln contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. 

The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated 

wtth manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted m the strict conditions outlined 

above, will provide an equtvalent level of safety supporting the grant of the exemptions requested 

herem, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a secure 

environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people. 

:~ ly subm2tat 

onathan Cook 

Windshear Media LLC. 

II