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 subpart 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 by 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 'blanket' COA for flights at or below 400 feet, within VLOS 

and safe separation from airports 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 July 23, 1978. I have several 

hundred hours in single-engine fixed wing and approx. 45 instrument hours 
toward my instrument certification.

BWP is a professional film production company with approx. 25 years of 

full service 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 within 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 333. 

We have used manned 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 crewmembers, 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. 

The risk to an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UAS 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 therefore 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 inflight 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 compared to a manned aircraft holding 

a restricted airworthiness certificate performing a similar operation. 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 therefore 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) Inspections, 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 limited 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 from 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 commercials and small 

projects. I would use the S-900 for documentaries and feature films where 

the expectation is of cinematic work using the Panasonic GH-4 camera.

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

area owned 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 security 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 interest. 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 conditions 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 than 55 lbs.

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

operating speed of no more than 35mph. 
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 depending on the 

UAS model in operation, 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 Operator (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 activities. 

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 Point (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 ensure 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 the 

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 communicate 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 21, 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 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. 

The UAS to be operated hereunder is 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 and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly 
controlled and monitored by both the operator and under the requirements 

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. Part 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 fuels, 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 lightsport 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 equivalent 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. The 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 levels 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 regulatory 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 

approved 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 there 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 immediate 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 

aircraft 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 exemptions 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 the 
aircraft 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 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, 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 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, and 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. 

Compared to flight operations 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 500 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 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 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 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 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 allowed 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 

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. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration. 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 civil 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 loaded 

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. 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. 

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 AGL. 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 maintain 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 considerations 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 of 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