John S. Duncan Director, Flight Standards Service Federal Aviation Administration 800 IndependenceAvenue SW Washington, DC 20591 Filed with www.regulations .gov

Docket FAA 2015-0480, Petition forAmendment 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 ReformAct 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 S1000were 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 payloadweight limited to 55 pounds

. Requested revisionsto 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 pilotswith 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 givethemthe requisite stick skills to precisely control the UAS. SFS, seeks approval to flywith experienced UAS operators in direct control of the craft,while under direct supervision of, and in direct communicationwith 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 craftwill be controlled by a skilled UAS operator instead of a newly trained UAS pilotwho 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 NationalAirspace System. SFS iswilling to provide a standard of tracking and security clearance for its non-FAA-licensed UAS pilots, such as aTWIC Card. SFS,will incorporate DJI’s pilot app for guided navigation systemto automate flight on closed-set film entertainment environments.Thiswill make flight pattern predictable and repeatable therefore enhancing the safety of those on set.The PIC andVOwill maintainVLOS on the craft at all times andwill be able to assume full control of craft at any time if any unpredicted eventwere 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 conductedwith manned helicopters or from the top of adjacent buildings. Granting this exemptionwill provide safer operationsthan using a helicopter, andwill have more flexibility and range than a stationery site on top of a building. In addition to the PIC andVO, SFS,will require a secondVO for these operationswhowill use an assisted-vision device such as a set of binoculars or a monoclewith nightvision technology.Additionally, SFS PICs and VOswill familiarize themselveswith the closed set during daylight hours in a preproduction scout.The UAVwill bewell litwith LEDs.SFS seeks a revisionto Condition 25 sothat 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 greatervisibility and directionality of the aircraft over long distances. Neitherthe PIC norVOwill betaskedwith operatingthe moving platform andwill remain completely focused on the operation of the UAS.The operation of a moving cart on a closed set, and by a personwho is neither the PIC nor aVO,will eliminate the risk of collisionwith any person not directly involved in the operation. SFS will comply with all other conditions and limitations imposed in Exemption No. 11590.

Thankyou foryour consideration of this petition. Sincerely,

Simon Feldman, President Simon Feldman Studio, Inc.