July 27 , 2015

From:
Michael Gould

6404 Manatee Ave. W.
Suite N Bradenton, Fl 34209 (941) 518

- 1548 mike.gould@mjgroup.us

Re : Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 s ubpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1 ) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Michael Gould dba Brave World Productions, LLC, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required by Section 333.

I am the majority shareholder and President of Brave World Production,

LLC (BWP), based in Bradenton, Florida. I would like to be considered
under the new 'blanke t' COA for flights at or below 4 00 feet, within VLOS

an d safe separation from airpor ts or heliports. Our (UAS) usage is for aerial photography /videography , real estate, motion picture and television operations. I have been a photographer for 35 years, a videographer for 5 years and a drone pilot for 3 years. I have been an FAA licensed private pilot since Jul y 23, 1978. I have several hundred hours in single

- engine fixed wing and approx. 45 instrument hourstoward my instrument certification. BWP is a professional film production company with approx. 25 years of
full s ervice video creation, editing, etc. throughout the U.S.

With regard to my initial Section 333 request for exemption, I will be using

a DJI S

- 900 and a DJI Inspire 1. I have been flying for three years without incident, and I keep a maintenance and flight log. My flights are always
beneath the 400

- foot level and are always withi n eyesight. I rarely fly near people and structures, as the majority of our work is scenic in nature. I am the only drone operator. The camera/gimbal operator uses a second remote

, which allows me to concentrate on safe operation of the drone while he captures the necessary footage. We have a third person on our crew who is tasked with security and safety on our production sets. We never fly the
drones over 10

- 15 MPH as we are not interested in speed, just in cinematic
effects. In accordance with the statutory criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USC 44704, and in consideration of the size, weight, speed, both aircraft meet the conditions of Section 33 3.
We have used m anned aircraft (fixed wing and helicopter) to conduct our aerial photography /videography operations in the past. However, these craft weigh thousands of pounds or more, are operated by an onboard pilot and may carry other onboard crewmemb ers, as well as carry large quantities of
fuel. Our pilot and crew will be remotely located from the aircraft. The limited weight and construction reduces the potential for harm to persons or damage to property in the event of an incident or accident.

Th e risk to an onboard pilot and crew during an incident or accident is
eliminated with the use of a U AS for the proposed operation. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or
accident. The UA carries no fuel and the refore the risk of fire following an incident or accident due to fuel spillage is eliminated. Both UAS have the capability to operate safely after experiencing certain in

flight contingencies or failures and both drones use an auto

- pilot system to
maintain UAS stability and control. Both UAS are also able to respond to a loss of global positioning system (GPS) or a lost

- link event with a pre

-coordinated, predictable, automated flight maneuver. These safety features provide an equivalent level of safety comp ared to a manned aircraft holding a restricted airworthiness certificate performing a similar op eration. Using
these machines will provide me with the ability to capture scenic aerial vistas for my customers, without resorting to the high cost, high noise, passenger, crew, fuel explosion danger, and waste of fossil fuels, thereby providing public benefit with limited impact. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. Both UAS carries no fuel, and therefor e the risk of fire following an incident or accident due to fuel spillage is eliminated. Request relief from 14 CFR 91.405(a) Maintenance required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(2) In spections, and 91.417(a) and (b) Maintenance records. Operating documents contain preflight and post flight checks for the UAS. Request relief from 91.409(a)(1) because of alternate inspection requirements of 91.409(a)(2). Operating documents, as should be sufficient to ensure that safety is not adversely affected.

Requested relief from 14 CFR 61.113(a) and (b), Private pilot privileges and limitations. I plan to operate in uncontrolled airspace

, and over private property with controlled access.
Given: 1 ) the similar nature of the petitioners proposed operating environment to that of Astraeus, 2) the parallel nature of private pilot aeronautical knowledge requirements to those of commercial requirements as discussed in Exemption No. 11062, and 3) the limi ted airmanship skills necessary to operate the UAS, the FAA found that the additional manned airmanship experience of a commercially certificated pilot, would not correlate to the airmanship skills necessary for the petitioners specific proposed operations

. However, a private pilot license, such as I have, provides a significant margin of safety in that I am fully aware of what pilots of large aircraft face and I have a knowledge base regarding the environment in which large aircraft and drones operate.I will operate the UAS in a manner consistent with and including evasive and emergency maneuvers while maintaining appropriate distances from people, vessels, vehicles, and structures. Request Relief from 14 CFR 91.121
Both UAS use information generated fr om GPS and compass to transmit : altitude , vertical and horizontal climb and descent speed, vertical and horizontal distance from PIC, battery life information , current and past route information, to the PIC. They are both capable of Return To Home (RTH) in the event of loss of radio signal or loss of battery power. Requested relief from 91.151(a) Fuel requirements. No fuel required. Requested relief from 91.151(a) Fuel requirements. No fuel required.

I would use the Inspire 1 for video work such as commer cials and small projects. I would use the S

- 900 for documentaries and feature films where the expectation is of cinematic work u sing the Panasonic GH

- 4 camera.

The applicant will operate the UAS in line of sight within a predetermined

area o wned and/operated by the property representative. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national sec urity issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public inte rest. Accordingly the applicant graciously requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and cond itions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh significantly less th an 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum

op erating speed of no more than 35 mph.3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be d epending on the UAS model in o peration, but will not exceed 30 minutes. Flights will be terminated at 30 % battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate,
Camera O perator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’ production ac tivities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic center/Airport Reference P oint (ARP) of a tower controlled or uncontrolled airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.

13 . The operator will obtain verbal/written consent of all persons involved with the planned operation and en sure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With th e advanced permission of the FSDO, operations at closer range may be a

pproved.14 . The PIC and VO will have been trained in operation of UAS and receive

up

- to

- date information for the particular UAS to be operated.

15 . The PIC and VO will be able to comm unicate by voice and/or radio at all times.

16 . Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations.

17 . If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously.

18 . The UAS will have the capability to abort a flight in case of emergencies with an automated “Return Home and Land” function.

19 . The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery.

14 C.F.R. Part 2 1, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 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 popula ted 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. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carrie s no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightlycontrolled and monitored by both the operator and under the requ irements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. P art 21, Subpart H. 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 f uels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft. The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or ligh tsport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). US Department of Transportation

February 20, 2015 The equi valent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) &(b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. T he proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk le vels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will be licensed private pilot. . It is believed that the operation and limitations set forth in the FOM will equate to the safe operation of the UAS.14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulato ry standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current

a pproved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because th ere is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have im mediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraf t an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exe mptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in t heaircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. 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 pr escribed, 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 AG L, 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, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where bu ildings 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, and speed of the UAS as well as the location where it is operated. No flight will be taken with out 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. Compared to flight operation s with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 5 00 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121 Altimeter Settings. This regulation requir es 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 U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site s hown 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 f orecast 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 applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be a llowed does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of bat tery 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.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registra tion. The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a c ivil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loa ded weighs well under the proposed 55lb limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. T hese 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 withan airworthiness certificate, these sections will not apply to th e applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet A GL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to mai ntain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance as needed.

Additional Information.

The applicant, Michael Gould , believes this exemption request and associated safety consi derations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficient justification for the granting of commercial operations of the applicant’s UAS.

The applicant, Michael Gould , requests your respective approval o f this Section 333 exemption petition request.

Please notify Michael Gould of your actions, and/or approvals. Thank you for your time and attention to this matter.

Sincerely,

Michael Gould, Brave World Productions, LLC

6404 Manatee Ave. W . Suite N, Bradenton, FL, 34209

mike.gould@mjgroup.us

(941) 518

- 1548