John S. Duncan

Director, Flight Standards Service

Federal Aviation Administration

800 Independence Avenue SW

Washington, DC 20591

Filed with www.regulations .gov

Docket FAA 2015-0480, Petition for Amendment to Exemption No. 11590;

We kindly request for Expedited Handling as we have been approached by

several film directors for upcoming filming.

Dear Mr. Duncan:

Simon Feldman Studio, Inc., which received FAA Exemption No. 11590 on May

14th ,2015 authorizing Simon Feldman Studio, Inc (SFS) under section 333 of

the FAA Modernization and Reform Act of 2012 to operate its DJI Phantom and

Inspire1 unmanned aircraft system ("UAS" ) for purposes of capturing high

definition feature film quality aerial cinematography, Real Estate and Television.

In this present petition for an amendment to Exemption No. 11590 , SFS. seeks

to operate three additional types of UASs the : (1) the DJI Phantom 2, (2) DJI

Phantom 3 and (3) the DJI S1000, for the purposes above as well as to request

these additional purposes, (including the DJI Inspire 1) namely agriculture,

inspections of oil and gas facilities, solar farms, wildlife preservation industries

and search and rescue operations, and to revise several conditions and

limitations set forth in Exemption No. 11590.

Requested addition of other UAS types and models

The airworthiness of the DJI Phantom 2, DJI Phantom 3, DJI S1000 were

previously determined by the FAA in Exemption No. 11150 (Aerocine, LLC),

Exemption No. 11481 (Explosives Risk Managers, LLC), and Exemption No.

(Geosky3, LLC).

The safety features and capabilities of the airframes listed above fit the

criteria listed in section 333 for payload weight limited to 55 pounds .

Requested revisions to several conditions and limitations

SFS, seeks a revision of conditions 1, 13, 15, and 25 of the Conditions and

Limitations set forth in amended Exemption No. 11590.
Condition 1 will need to be revised to include theDJI Phantom 2, DJI Phantom 3

Professional, DJI S1000, and as requested above.

SFS, seeks a revision to Condition 13. Expertly piloting a UAS for the motion

picture entertainment industry and Television is a particular skill only a small

number of people have developed. SFS is currently restricted to pilots with an

FAA private, recreational or sport pilot license. SFS has found most such

certificated pilots to be unqualified to fly our UASs. Their manned aircraft

training and experience does not give them the requisite stick skills to precisely

control the UAS.

SFS, seeks approval to fly with experienced UAS operators in direct control of

the craft, while under direct supervision of, and in direct communication with

an FAA-licensed private, recreational, or sport pilot as a VO, as requested in

our original petition Docket No. FAA-2015-0460. This increases safety of the

operation as the craft will be controlled by a skilled UAS operator instead of a

newly trained UAS pilot who has a private pilot license.

Having an FAA-licensed private, recreational, or sport pilot as a VO will ensure

SFS adherence to all rules of National Airspace System. SFS is willing to

provide a standard of tracking and security clearance for its non-FAA-licensed

UAS pilots, such as a TWIC Card.

SFS, will incorporate DJI’s pilot app for guided navigation system to automate

flight on closed-set film entertainment environments. This will make flight

pattern predictable and repeatable therefore enhancing the safety of those on

set. The PIC and VO will maintain VLOS on the craft at all times and will be able

to assume full control of craft at any time if any unpredicted event were to

occur such as the UAV deviating from its flight path.

SFS seeks a revision to Condition15 to fly its UAVs during both day and night

times on closed entertainment sets. Nighttime filming operations, which are

absolutely necessary for certain portions of certain entertainment filming, are

frequently conducted with manned helicopters or from the top of adjacent

buildings. Granting this exemption will provide safer operations than using a

helicopter, and will have more flexibility and range than a stationery site on top

of a building. In addition to the PIC and VO, SFS, will require a second VO for

these operations who will use an assisted-vision device such as a set of

binoculars or a monocle with night vision technology. Additionally, SFS PICs and

VOs will familiarize themselves with the closed set during daylight hours in a

preproduction scout. The UAV will be well lit with LEDs.
SFS seeks a revision to Condition 25 so that it may fly its UASs from a moving

platform on a closed film set. SFS is aware that this technique has been used

successfully in foreign countries by aerial filming companies, operating UASs

from moving platforms such as boats, cars, and golf carts. This is often done to

help the pilot maintain greater visibility and directionality of the aircraft over

long distances. Neither the PIC nor VO will be tasked with operating the moving

platform and will remain completely focused on the operation of the UAS. The

operation of a moving cart on a closed set, and by a person who is neither the

PIC nor a VO, will eliminate the risk of collision with any person not directly

involved in the operation.

SFS will comply with all other conditions and limitations imposed in Exemption

No. 11590.

Thank you for your consideration of this petition.

Sincerely,

Simon Feldman, President

Simon Feldman Studio, Inc.