R Relentless Studios, LLC 

112 Moss Rock Lane I Irondale, AL 35210

P: (205) 602-1991 I E: kkey@moonmenonline.com

November 06th, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE, 

West Building Ground Floor, Room Wl2-140, 

Washington, DC 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Refon:ri'Act 

and Part II of the Federal Aviation Regulations from 14 C.F.R. 61.IB(a) and (b); 

91.119(c); 91.121; 91.151(a)(I); 91.405(a); 91.407(a)(I); 91.409(a)(I) and (2); 

91.417(a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part II, Relentless Studios, LLC; operator of Small Unmanned Aircraft 

(UA) equipped to conduct aerial photography for the motion picture and television industry 

for scripted closed set filming, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow commercial operation of its UA, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

1

Relentless Studios, LLC requests that the publication and comment procedures be 

waived in accordance with 14 C.F.R. § 11.87 which states: 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of

my petition for exemption?

The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously.

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a 

Certificate of Waiver for Motion Picture and Television Filming. 
• Relentless Studios, LLC

( c) Whether our delaying action on your petition would affect you adversely.

( d) Whether you filed your petition in a timely manner.

Corresponding to the above sub-sections, Relentless Studios, LLC has good cause to 

request the FAA to waive the comment period and not delay action on the petition because: 

(a) Relentless Studios, LLC would not set any precedent. Exemption #'s 11062, 11063, 

11064, 11065, 11066, 11067, 11080 are all previously granted petitions to "allow 

operation[s] of unmanned aircraft systems (UAS) for the purpose of scripted, closed-set 

filming for the motion picture and television industry." Relentless Studios, LLC agrees to 

the SAME exact limitations as the above listed exemptions, which are included below, 

"for the purpose of scripted, closed-set filming for the motion picture and television 

industry."

(b) This petition for exemption is requesting relief identical to the above mentioned seven 

petitioners. The regulations that Relentless Studios, LLC is seeking relief from were 

chosen based directly upon the FAA's chart included in the seven exemptions mentioned 

above listing which regulations needed exempting. This was done so that the FAA could 

waive the comment period and rapidly grant this petition. Furthermore, much of the 

petition below is copied directly from the petitions of the seven, except we have 

eliminated certain flawed parts ( communication between the spotter and pilot via text, 

etc.) and made minor edits to the spelling, citations, or style.

(c) Delaying the granting of this petition would adversely affect the public. the FAA. and 

Relentless Studios, LLC. The public, as well as the FAA, would be better served by the 

FAA quickly granting this petition and thereby freeing up limited FAA resources and 

allowing FAA inspectors to dedicate their time and attention to much higher priorities. 

Moreover, Wild Rabbit Productions is eagerly seeking to start commercial operations and 

is adversely affected by the above listed regulations.

(d) The petition has been filed in a timely manner. 

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• Relentless Studios, LLC

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive UAS under controlled conditions in airspace that is: 

1) limited; 2) predetermined; 3) controlled as to access; and, 4) would provide safety

enhancements to the already safe operations in the film and television industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation's (the FAA Administrator's) responsibilities to "establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 

Section 333(c) of the Reform Act. 

Petitioner's contact info: 

Relentless Studios, LLC

Attn: Kevin Key 

Phone: 205-602-1991 

Email: kkey@moonmenonline.com 

Address: 112 Moss Rock Lane - Irondale, AL 35210 

Regulations from which theexemption is requested: 

• 14 C.F.R. § 61.113(a) & (b)

• 14 C.F.R. § 91.119(c)

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)(l)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(l)

• 14 C.F.R. § 91.409(a)(l) & (2)

• 14 C.F.R. § 91.417(a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the FAA 

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• Relentless Studios, LLC

Modernization and Reform Act. In making this determination, the Secretary is required to 

determine which types of UA do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 

• The UA's size, weight, speed, and operational capability;

• Operation of the UA in close proximity to airports and populated areas; and,

• Operation of the UA within visual line of sight of the operator (VLOS).

Reform Act § 333(a). Lastly, 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." Id.§ 333(c) (emphasis added).2

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 that includes UAS's, from the requirement that all civil aircraft must 

have a current airworthiness certificate. 

"The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if

the Administrator finds the exemption in the public interest." 49 U.S.C. § 44701(f). See also 49 

u.s.c. § 4471l (b).

Relentless Studios, LLC UA are rotorcraft, weighing 55 lbs. or less including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and they have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only within VLOS and only within the sterile area described in the Confidential Motion 

Picture and Television Operations Manual and Flight Operations and Procedures Manual 

attached as Exhibit 1 (hereinafter "the Operating Manual").3 Such operations will insure that 

the UAwill "not create a hazard to users ofthe national airspace system or the public."4 

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it 

should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 

3 FAA Licensed Commercial Pilots, a Certified Flight Instructor, a FAA Designated Engineering Representative, 

and members of the motion_picture indt1stry have reviewed this manual and__have found it acceptable for UA flight 

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• Relentless, Studios, LLC

Given the small size of the UA involved and the restricted sterile environment within 

which they will operate, the applicant falls squarely within that zone of safety ( an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations ofUA to commence immediately. Also, due to the size ofthe UA and the 

restricted areas in which the relevant UA will operate, approval of the application presents no 

national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including enhanced 

safety, reduction in environmental impacts, including reduced emissions associated with 

allowing UA for movie and television operations, the grant ofthe requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to the 

already safe movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions, taken directly from the seven exemptions granted to 

film companies (Exemption #'s 11062, 11063, 11064, 11065, 11066, 11067, 11080), •

Relentless, Studios, LLC agrees to be bound when conducting commercial UA operations. 

These limitations have already been written and incorporated into the Operating Manual. The 

list oflimitations and conditions include the following: 

operations in the film and television industry. Applicant submits this manual as a Confidential document under 14 

C.F.R. § l 1.35(b) as the entire manual contains proprietary information that the applicant has not and will not

share with others. The manual contains operating conditions and procedures that are not available to the public

and are protected from release under the Freedom of Information Act 5 U.S.C. § 552 et. seq.

4 Reform Act Section 333(b). 

. . 

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• Relentless, Studios, LLC

1. The UA weighs less than 55 pounds, including batteries and camera gimbal. Operations 

requested in this petition for exemption are limited to the following aircraft described in 

the proprietary operator's manual: DJI Phantom 3 Professional. Proposed operations of any 

other UA will require a new petition or an amendment.

2. The UA shall not be flown at a speed exceeding a ground speed of 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All altitudes 

reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). 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.

6. The operator's manual shall be maintained and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations in this exemption 

and the procedures outlined in the operator's manual, the conditions and limitations 

herein take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operator's manual. The operator may update or revise its 

operator's manual. It is the operator's responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment. If the 

operator determines that any update or revision would affect the basis of this exemption, 

then the operator must petition for amendment to their exemption. The FAA's UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operator's manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight If tlle inspection reveals a condition tll_a t affects tl1e safe operation of the UAS, the 

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• Relentless, Studios, LLC

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. The Ground Control Station 

shall be included in the preflight inspection. All maintenance and alterations shall be 

properly documented in the aircraft records. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight in accordance with the operator's manual. The PIC who conducts the

functional test flight must make an entry in the UAS aircraft records of the flight. The

requirements and procedures for a functional test flight and aircraft record entry are

included in the operator's manual.

9. The operator shall follow the manufacturer's UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. An aircraft maintenance

manual with maintenance/component/overhaul, replacement, and inspection/maintenance

requirements has been established and included in the operator's manual.

10. The Pilot In Command (PIC) shall possess at least a private pilot certificate and at least a

current third-class medical certificate. The PIC must also meet the flight review

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on

his/her pilot certificate.

11. Prior to operations conducted for the purpose of motion picture filming ( or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51 (b ), a minimum of 200 flight cycles and 25 hours of total time as a UAS

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type 

(single blade or multirotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations 

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• Relentless, Studios, LLC

are considered non-participants, and the PIC must operate the UA with appropriate 

distance from non-participants in accordance with 14 C.F.R. § 91.119. 

12. Prior to operations conducted for the purpose of motion picture filming, the PIC must

have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51 (b), a

minimum of five hours as UAS pilot operating the make and model ofUAS to be utilized

for operations under the exemption and three take-offs and three landings in the

preceding 90 days. During training, proficiency, experience-building, and take-off and

landing currency 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 C.F.R. § 91.119.

13. Prior to operations conducted for the purpose of motion picture filming, the PIC and

visual observer (VO) must have successfully completed a qualification process, as

outlined in the operator's manual. The test has been developed by the operator and shall

be implemented by a qualified person designated at the sole discretion of the operator. A

record of completion of this qualification process must be documented and made

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming, a flight

demonstration, administered by an operator-approved and qualified pilot must be

successfully completed and documented. This documentation must be available for

review upon request by the Administrator. Because the knowledge and airmanship test

qualifications have been developed by the operator, the petitioner will conduct these tests

in accordance with the operator's manual.

15. The UA may not be operated directly over any person, except authorized and consenting

production personnel, below an altitude that is hazardous to persons or property on the

surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator's manual has safety

mitigations for authorized and consenting production personnel. At all times, those

persons must be essential to the closed-set film operations. Because these procedures are

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• Relentless, Studios, LLC

specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) 

approval is necessary for reductions to the distances specified in the petitioner's manuals. 

This is consistent with the manned aircraft procedures described in FAA Order 8900.1, 

V3, C8, Sl Issue a Certificate of Waiver for Motion Picture and Television Filming. 

17. Regarding distance from non-participating persons, the operator must ensure that no

persons are allowed within 500 feet of the area except those consenting to be involved

and necessary for the filming production. This provision may be reduced to no less than

200 feet if it would not adversely affect safety and the Administrator has approved it. For

example, an equivalent level of safety may be determined by an aviation safety

inspector's evaluation of the filming production area to note terrain features, obstructions,

buildings, safety barriers, etc. Such barriers may protect non-participating persons

(observers, the public, news media, etc.) from debris in the event of an accident. This is

also consistent with the same FAA Order 8900.1, V3, C8, SL

18. If the UA loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance

with the operator's manual.

19. The UA must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator's manual.

20. Each UA operation must be completed within 30 minutes flight time or with 25% battery

power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting any operations under this grant of exemption.

This COA will also require the operator to request a Notice to Airman (NOTAM) not

more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 4 7, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, subpart C. Markings must be as

. large as practicable. 

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• Relentless, Studios, LLC

23. The operator has developed procedures to document and maintain a record of the UA

maintenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the UA.

24. Each UA must comply with all manufacturer Safety Bulletins and firmware updates.

25. The operator has developed UA technician qualification criteria and they are included in

the operator's manual.

26. The preflight inspection accounts for all discrepancies, i.e. inoperable components, items,

or equipment, not covered in the relevant preflight inspection sections of the operator's

manual.

27. The radio frequency spectrum used for operation and control of the UA complies with the

Federal Communications Commission (FCC) or other appropriate government oversight

agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction

over the area of proposed filming. The 3-day notification may be waived with the

concurrence of the FSDO. The requirements for a plan of activities and a sample form are

in the operator's manual.

29. The documents required under 14 C.F.R. § 91.9 and § 91.203 must be available to the

PIC at the ground control station of the UAS any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

30. The UA must remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute

activities, parasailing activities, hang gliders, etc.).

31. UA operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

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• Relentless, Studios, LLC

32. The UA cannot be operated by the PIC from any moving device or vehicle.

33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

34. The UA may not operate in Class B, C, or D airspace without written approval from the

FAA. The U A may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a letter

of agreement with that airport's management is obtained, and the operation is conducted

in accordance with a NOTAM as required by the operator's COA. The letter of agreement

with the airport management must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to

the Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board (NTSB)

per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight

operations may not be conducted until the incident, accident, or transgression is reviewed

by AFS-80 and authorization to resume operations is provided.

Unless otherwise specified by the Administrator, the PIC, and operator must comply with all 

applicable parts of 14 C.F.R. including, but not limited to, parts 45, 47, 61, and 91. 

ST AT UT O RY C R I T E R I A PROV I D E D I N SE CT I O N 333 

The UA proposed to be operated by the applicant weighs less than 55 lbs. fully loaded, 

carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area as outlined in the operator's manual. Unlike other civil 

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

operator, pursuant to the criteria in the operator's manual, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as 

is now done with conventional filming. The FAA will have advance notice of all operations and 

has issued the aforementioned list of conditions and limitations. These safety enhancements, 

which al�eady apply to civil aircraft operated in c()11nection with tnotio�picture and television 

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• Relentless, Studios, LLC

production, provide a greater degree of safety to the public and property owners than 

conventional operations. Lastly, application of these same criteria 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. 

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 airports and 

populated areas of the particular UAS. In all cases, an analysis 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. 

As there will be no airworthiness certificate issued for the unmanned aircraft, and no FAA 

regulatory standard will exist for determining airworthiness of the UA, the requirements 

contained in the operator's manual for maintenance and use of safety check lists prior to each 

flight, will provide an equivalent level of safety. 

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an 

onboard pilot, there is no ability or place to carry certification and registration documents or to 

display them on the unmanned aircraft. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the pilot flying the UA will have immediate 

access to them. Given the size of the unmanned aircraft, the FAA registration number will be 

displayed on the airframe in as large a font as possible. 

14 C.F.R. § 61.113 (a) & (b): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN

COMMAND. 

Sub-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 safety of current operations by requiring the PIC operating the aircraft 

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• Relentless, Studios, LLC

to have a private pilot's license rather than a commercial pilot's license to operate this small 

UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is 

remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the Operating 

Manual. The level of safety provided by the requirements included in the Operating Manual 

exceeds that provided by a single individual holding a commercial pilot's certificate 

operating a conventional aircraft. The risks associated with the operation of the UAS are so 

diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the UAS 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). 

14 C.F.R. § 91.119: MINIMUMSAFEALTITUDES

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

( d) allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescribed for helicopters 

by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated 

platform from which filming is planned, an exemption may be needed to allow such 

operations. As set forth herein, except for the limited conditions stated in the Operating 

Manual, the UAS will never operate higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, 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, speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be aware 

of the planned flight operations as set forth in Chapters 1 and 13 of the Operating Manual. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk associated with 

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these operations is far less than those presently presented with conventional aircraft operating 

at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the 

UAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.121: ALTTMETER 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 UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

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

VFR 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 UAS provides approximately 40 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, UAS 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. 

Applicant believes that an exemption from 14 C.F.R. § 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 engender the type of risks that 

Section 91.151 (a) was intended to ctllevi_ate given the size and speed of the small UAS. 

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Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 

30 minutes or 25% of battery power whichever happens first. This restriction would be more 

than adequate to return the UAS 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 

14 C.F.R. § 91.405 (a); § 407 (a) (1); § 409 (a) (2); § 417(a) & (b): MAINTENANCE

INSPECTIONS 

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

inspected as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph ( c) of this section, have discrepancies repaired as prescribed in part 43 of 

this 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 airworthiness 

certificate, these sections will not apply to the applicant. An equivalent level of safety will be 

achieved because these small UAS's are very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS 

can land immediately and will be operating from no higher than 400 feet AGL. As provided in 

the Operating Manual, Chapters 11 and 12, the operator will ensure that the UAS is in working 

order prior to initiating flight, will perform required maintenance, and will keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. 

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 following rules: 

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14 C.F.R. 61.113(a) and (b); 91.119(c); 91.121; 91.151(a)(l); 91.405(a); 91.407(a)(l); 

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

(55 lbs. or less) in motion picture and television operations. 

Approval of exemptions allowing commercial operations of UAS 's in the film industry 

will enhance safety by reducing risk. Conventional film operations, using jet or piston 

power aircraft, operate at extremely low altitudes just feet from the subject being filmed 

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

aircraft that weigh in the neighborhood of 4,000 lbs., carrying large amounts of jet A or 

other fuel (140 gallons for jet helicopters shown below). Such aircraft must fly to and 

from the film location. In contrast, a UAS 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 UAS is carried to the film set and not flown. The 

UAS will carry no passengers or crew; therefore, it will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment and, as a result, are far safer than 

conventional operations conducted with turbine helicopters operating in close proximity 

to the ground and people. 

DRUG AND ALCOHOL TESTING 

The previous seven exemptions granted did not mention alcohol or drug testing; however, 

Relentless, Studios, LLC has drug and alcohol testing procedures and a handbook which 

are included in Chapters 14 and 15 of the Operating Manual. This further goes to mitigate any 

safety concerns. 

PRIVACY 

All flights will occur over private or controlled access property with the property owner's 

p1for consent <llld knowledge. Filming will be �f reople who have also consented to being filmed 

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• Relentless, Studios, LLC

or otherwise have agreed to be in the area where filming will take place. The grant of this 

exemption request will provide improved safety over the use of manned aircraft. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security - provides more than adequate justification for 

the grant of the requested exemptions allowing commercial operation of applicant's UAS in the 

motion picture and television industry pursuant to the Operating Manual appended hereto. 

Sincerely yours, 

Kevin Key, Operating Partner 

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