## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

1 of 2 May 9, 2015

U.S. Department of Transportation, Docket Operations Attn: Federal Aviation Administration (FAA) Administrator West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590
Dear Administrator, Orlando Production Inc. (OPI) would like the Federal Av iation Administration (FAA) to consider this letter as its formal Section 333, Waiver and Exemption. As a leader in the digital photography and cinematic industries. OPI caters to a wide variety of photogra phic needs required to support of its clients, both private and commercial. OPI has assembled a uniquely qualified aerial imagin g team with extensive qualifications to ensure quality and safe small Unmanned Aircraft System (s UAS) operations. The team ’s qualifications include over 20 years of cinematic and photographic imaging and 15 years of experience in FAA Part 61, 65, and 141 pilot training, maintenance, and commercial flight operations. Understanding the overwhelming demand for aerial photography and now more accessible with the advent of Unmanned Aerial Systems (UAS), OPI has po sitioned itself to provide and answer this need in a safe and professional manor.
Orlando Production Inc. commends the Federal Aviati on Administration’s (FAA) for its recent action in publishing the proposed sUAS rule. OPI understand s that until the new rule becomes law that the FAA still needs to ensure the safety of the NAS (National Airs pace System) for all users. This collective goal is the motivation for OPI to employ subject matter experts (SME’s) from both the aviation and photography industries. Furthermore, OPI’s aerial sUAS division will adopt industry accepted “best practices” as its processes and procedures to al low for safe and successful sUAS operations. At this time, OPI has invested in professional gr ade sUAS platforms, as well as, imaging and sensing devices in an effort to provide its clients with a vari ety aerial services. In doing so, OPI will only employ qualified Pilot/Observer operators who are familiar with Federal Av iation Regulations (FAR) and the guidance and/or restrictions provided fo r in the approval of this exemption. Furthermore, DroneLife.com sited a Bloomberg repor t stating that Amazon has sold more than 10,000 devices per month in 2014. With over 1 million UAS platforms in operation today, OPI is looking to provide the safety of proven aviation operational standards to meet the demand for private and commercial imaging while ensuring UAS operations ar e also conducted within the legal guidelines that this exemption will provide.

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

2 of 2 It is the sincere hope of Orlando Production, Inc. and its staff, that the Administrator grant this exemption as it believes it has met the congression al mandate to “operate safely in the National Airspace System.” Please find attached OPI’s regulato ry compliance of title 14 CFR §11. 81 regarding the petition for an exemption allowed for under Public Law 112-95 §333. Respectfully,

Nicholas Schultz Orlando Production, Inc. Director of Aerial Operations 8761 Atwater Loop Oviedo, FL 32765 C: 321-438-2672 Nick@OrlandoProduction.com exemption allowed for under

R espectfully,

N i cholas Schul tz Or la nd o Pr od uc ti on In c

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

1 of 7 

## I n f o r m a t i o n S u p p o r t i n g O r l a n d o P r o d u c t i o n , I n c
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A. Mailing address and other contact information:
Orlando Production, Inc. Attn: Nicholas Schultz 8761 Atwater Loop Oviedo, FL 32765 C: 321-438-2672 Nick@OrlandoProduction.com Orlando Production, Inc. Attn: William Shanley 8761 Atwater Loop Oviedo, FL 32765 C: 407-765-8210 Bill@OrlandoProduction.com

B. The specific section or sections of 14 C.F.R from which Orlando Production, Inc. (OPI) seeks exemption:
OPI seeks exemption from applicable title 14 Code of Federal Regulations (CFRs) relevant to small Unmanned Aircraft System (sUAS), as defined by the FAA, operations. The belo w list, includes but is not limited to, regulations limi ting sUAS operations.
1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 3. 49 USC § 44711 Prohibitions and exemption 4. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 5. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 6. 14 CFR 91.119 Minimum Safe Altitudes. 7. 14 CFR 91.121 Altimeter Settings. 8. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 9. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations. 10. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Me dical and Paragraph 16(e)(1) Observer Medical.

C. The extent of relief, and the reason for relief:
Orlando Production, Inc. is requesting relief from mu ltiple regulatory constraints under title 14 CFR Parts 21, 45, 61, 65, 91 as well as other UAS regulatory guidance under FAA Notice 8900.227, Public Law 112- 95, Title 49 United States Code (USC), with regar ds to Unmanned Aircraft System (UAS) operations, more specifically sUAS commercial operations. OPI would like, with the permission of the Administ rator, to provide sUAS aerial imaging and sensing with the intended use to include but not limit the following:

x Aerial services including

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

2 of 7 o Photography

o Cinematography

o Survey Detailed below is a list of operational safeguards OPI believes are essential for safe operations of which many have been previously approved by the Admini ster for similar sUAS operations. In addition, OPI will not commence sUAS operation that will create an undue hazard to users of the national airspace system (NAS), the public, or pose a threat to national security. OPI has published and/or adopted the following documents to be an integral part of its sUAS operations.

x OPI Flight Operations Manual (Flight Ops Manual)

x Motion Picture and Television Operations Manual (MPTOM)

x DJI Published

x User Manuals

x Maintenance Manuals

x Propeller Locks Manuals

x Safety Guidelines

x Flight Battery Safety Guidelines

x Release Notes

x Lightbridge (optional)

x Lightbridge User Manual

x OPI Published

x Pilot’s Operating Manual (POH)/Aircraft Flight Manual (AFM)

x Spreading Wings S1000+

x Mission Planner/Firmware

x User Manuals

x Planning Manuals Furthermore, OPI will ensure all operations are in co mpliance with these documents and/or other more recent and relevant documents that OPI determines will improve the safety and crew resource management (CRM) of the OPI aerial team. OPI believes the this request is consistent with the congressional mandate in Section 333 of the FAA modernization and Reform Act of 2012 and will allow OPI to operate sUAS in a legal, safe, and publicly beneficial way which exceed the standards currently permitted for recreational use.

D. The reasons why granting Orlando Production, Inc.’s request would be in the public interest; that is, how it would benefit the public as a whole:
By the granting of this exemption the public will bene fit from the worldwide well-publicized benefits of UAS operations which include:

x Public safety

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

3 of 7 x United States infrastructure

o Bridges inspection

o Building inspection

o Utility inspection

 Power

 Communication

x Unimproved Property Imaging

o Agricultural

 Surveying

 Crop Inspection

x Improved Property Imaging

o Commercial and Residential

o Structural inspection

o Exterior appliance inspection

x Economic Development Benefits

x Marketing The benefits of sUAS operations is exhaustive and the uses of these devised will allow public, private, and personal entities to benefit from the expertise OPI has to offer while miti gating the physical safety hazards of the current legally approved imaging meth ods as well as the cost reduction made possible by sUAS platforms. OPI is confident that the granting of this exemption will allow OPI to continue providing a high quality solutions for its client base while minimizing the risk of accidents and/or damage to persons or property. The positive impacts will be felt by the families of our employees, the improved safety of our neighbors, and our community as a whole.

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which Orlando Production, Inc. seeks the exemption:
As documented above, OPI’s sUAS operational procedu res will provide a level of safety that far exceeds the level of safety currently required by the FAA fo r hobbyist and manufacturers of model aircraft. The following operating procedures will apply during all sUAS operations under this exemption.
1. The below chosen sUAS(s) will not exceed the operational weight or maximum gross takeoff weight (MGTOW) as defined by the FAA and currently limited to a MGTOW of 55 pounds. i. DJI
a. Phantom Series b. Inspire Series
c. Spreading Wings S1000+
a. Optional

x DJI Lightbridge (Advan ced Datalink System)

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

4 of 7 2. Approved airframes will not exceed an airspeed of 87 knots (100 miles per hour) or “maximum never-exceed speed (V NE )” published and/or recommended by the airframe manufacturer, whichever is lower. 3. sUAS operations will not exceed the reported absolu te altitude of 400 feet or 50 feet above and 50 feet laterally from the highest point of the target structure. 4. All sUAS Pilot in Command (PIC) will operate with visual line of sight (VLOS) at all times where the VLOS will be human unaided vision by any de vise other than corrective lenses as specified on the PIC’s FAA-issued ai rman medical certificate or U.S. driver’s license. 5. Operations requiring the use of Visual Observers (VO) i. All sUAS operations not employing geo-fencing technology, where geo-fencing technology is a technology that utilizes th e onboard GPS with software to create a virtual boundary around the target structure ii. All operations operating more than 50 feet laterally of a target structure and/or a reported absolute altitude over 200 feet iii. All operation where individuals not associated with the operation are within the vicinity 6. Visual Observer requirements i. The sUAS must be operated within the visual li ne of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is no t permitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must ensure th at the VO can perform the duties required of the VO. 7. The PIC must have all available information req uired to ensure successful flight. This information must be accessible during sUAS operations. i. All available information must incl ude the following, at a minimum:
a. All documents needed to operate the sUAS and conduct its operations in accordance with the conditions and li mitations stated in this grant of exemption, are hereinafter referred to as the operating documents. b. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the op erating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revise its operating documents.
c. It is the operator’s responsibility to tr ack such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. d. The operator must also present updated and revised documents if it petitions for extension or amendment to this gr ant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the op erator must petition for an amendment

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

5 of 7 to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any sUAS that has undergone maintenance or altera tions that affect the UA S operation or flight characteristics, e.g. replacement of a flight crit ical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must re main at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and in specting the UAS to ensu re that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre-fl ight inspection and dete rmine the UAS is in a condition for safe flight. The pre-flight inspec tion must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufact urer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comp ly with all manufacturer safety bulletins. 13. The PIC must hold a certificate issued under 14 CFR Part 61. The PIC must also hold a curren t FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. 14. OPI will not permit any PIC to operate unless th e PIC demonstrates the ability to safely operate the UAS in a manner consistent with how th e UAS will be operated including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. i. OPI will only utilize a PIC who has complete d standardized training and has a minimum of 25 hours of documented flight experience in sUAS operations and at least 5 hours on each device type and category prior to any exempted commercial operation. ii. PIC qualification flight hours and currency mu st be logged in a manner consistent with 14 CFR § 61.51(b). Flights fo r the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-build ing) and determining the PIC’s ability to safely operate the sUAS in a manner consistent with how the sUAS will be operated under this exemption are permitted under th e terms of this exemption. However, training operations may only be conducted duri ng dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

6 of 7 15. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me teorological conditions (VMC). 16. The unmanned aerial vehicle UAV may not operate at or above a reported absolute altitude of 500 feet within 3 nautical miles of an airpor t reference point (ARP) as denoted in the current FAA Airport/Facility Dire ctory (A/FD) or for airports without a published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request. i. The UAV may operate above a reported absolute altitude of 500 feet providing OPI has gained prior written approval from the air tr affic authority responsible for the restricted airspace. 17. The UAV may not be operated less than 500 feet be low or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAV loses communications or loses its GPS signal, the UAV must return to a predetermined location within the private or controlled-access property. 19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power fo r the UAV to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. All aircraft operated in accordan ce with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, an d have identification (N- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the ai rcraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 23. The UAV must remain clear and give way to all ma nned aviation operations and activities at all times. 24. The UAS may not be operated by the PIC from any moving device or vehicle. 25. All flight operations must be conducted at leas t 200 feet from all nonparticipating persons, vessels, vehicles, and structures unless: i. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UAV and/or debris in the event of an accident. The operator must ensure where nonparticipating persons leave such protecti on and are within 200 feet of the UAV, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and ii. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk

## O r l a n d o P r o d u c t i o n , I n c
. 8761 Atwater Loop Oviedo, F lorida 32765

7 of 7 of operating closer to those objects and de termined that it does not present an undue hazard. The PIC, VO, operator trainees or essential p ersons are not considered nonparticipating persons under this exemption. 26. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authoriz ed representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applic able COA must be repo rted to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per inst ructions contained on the NTSB Web site: www.ntsb.gov. 28. Closed-set motion picture and television filmin g and production OPI will observe and abide by all procedures as is contained in a motion pictur e and television operations manual (MPTOM). 29. For flight operations closer than 200 feet from participating persons consenting to be involved and necessary for the filming production will be conducted in accordance with and as specified in OPI’s MPTOM.

F. Additional information and view:
Orlando Production, Inc. would ask that the Administrator consider all previously awarded exemptions as supporting arguments to this exemption request. Additionally, due to file size limitations of the FAA electronic comment/request system, OPI will provide, upon request, detailed specifications, operational pr ocedures, and optional equipment documentation.
OPI would like to thank the FAA for its consideration as our team awaits a positive outcome to this request. Should the Administrator require any additional information or clarification please do not hesitate to contact myself or Mr. William Shanley directly.

Respectfully,

Nicholas Schultz Orlando Production, Inc. Director of Aerial Operations 8761 Atwater Loop Oviedo, FL 32765 C: 321-438-2672 Nick@OrlandoProduction.com R espectfully,

N i cholas Schul tz Or la nd o Pr od uc ti on In c