# The Visual Arts Group, LLC

Media in Motion www.thevisualartsgroup.com

July 6 , 2015

U.S Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Amendment to Exemption No 11733 Issued to The Visual Arts Group, LLC pursuant to Section 333 of the FAA Reform Act (Docket No. FAA

- 2015

- 0036 )

Dear Gentlemen:

The Visual Arts Group, LLC was issued exemption No. 11733 on June 2, 2015 (hereafter “the Exemption”) allowing the petitioner to operate a UAS to perform aerial data collection and closed set motion picture filming. The Vi sual Arts Group, LLC hereby requests an amendment to the exemption
that will allow the PIC to operate a UAS from a moving vehicle.

This request for amendment specifically addresses rule #25 within the Conditions and
limitation s that prohibits the opera tion of a UAV from a moving vehicle or devise. Should this amendment be granted

, all other c onditions and l imitations listed under “Conditions and Limitations” as specified under this Exemption would be adhered to. The Visual Arts Group, LLC believes that an amendment allowing UAV operation from a moving vehicle is in the public’s interest as it would reduce
the distance between the PIC and the UAV.

A constant short er distance between the UAS and PIC can be maintained at all times. The closer proximity be tween the PIC and UAS would facilitate more precise and safer camera shots. The moving vehicle would be opera ted at speeds at or below 25mph and would add increase d safety to the line of sight distance limit, as specified in the “Conditions and Limitations ” of the Exemption. The moving
vehicle amendment will allow the PIC to follow and film an action scene down a path or roadway while operating under the operating procedures set forth in the Movie Production and Television Operations Manual (MPTOM). Exampl es of moving vehicles would be golf carts, camera dollies and other slow moving vehicles customarily use d on motion picture and TV sets for the purpose of transporting movie cameras during the filming process. The moving vehicles would be operated within safety boundaries clearly set up and marked for the purpose of safety to all personal and equipment located within the movie and TV production “sterile set” area of operation.An additional crew member beyond the spotter , camera operator and PIC will be utilized as a

driver/operator of the moving vehicle transporting the PIC. The moving vehicle will not have any obstructed view of the flight area such as a roof over the area where the PIC is located on the vehicle

. The vehicle will be open above the PIC with a 360 degree overhead view of the area of UAS operations. The moving PIC vehicle will operate only in the designated “sterile area” of the set.

The Visual Arts Group, LLC respectfully submits that this amendment qualifies for summary grant approval. Grant of Exemption to The Visual Arts Group, LLC , Exemption No. 11 733 . Given that the proposed operations will fully comply with the other conditions of the Exemption, there is no need for the FAA to repeat the analysis performed for the original exemption on which this amendment is based. For these same reasons, good cause exists so that notice does not need to be published in the Federal Register for the requested amendment. If you have any questions, or need any additional information to

proces s the requested amendment to allow UAS operations from a moving vehicle for the purpose of
closed

- set motion picture and television filming, please do not hesitate to contact the undersigned.

Very Truly Yours,

Wm. Howell Upchurch
President
The Visual Arts Group, LLC