## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

1 Cranial	Thunder ,	LLC

Mr. Brett	M.	Thorson,	Owner
6920B	Braddock	Rd.	#150 Annandale,	VA	22003

December	30 th ,	2015



## Summary
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	91.105 ; 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)

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(th e	“Reform	Act”)	and	14	CFR	Part	11, Cranial
Thunder ,	LLC ,	operator	of Unmanned	Aircraft	System s (UAS) and	small	Unmanned	Aircraft	Systems	(sUAS) (hereinafter	UAS)

, hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	(“FARs”)	to allow	commercial	operation	of	its	UAS, 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.

Following the	Section	333	waiver	request is	the	Motion	Picture and	Television	Operations	Manual	(MPTOM) from	Cranial	Thunder,

LLC required by	Order	8900.1,	Volume	3,	Chapter	8,	Section	1 to	allow	the	operation	of	UAS	in	closed

- set	filming.



## Proposed	Operations

Co mmercial	operation	of UAS,	as	described	herein,	which	are equipped	with	camera(s)	and	sensors,	would	operate	in	the following	manner:

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	architecture,	land	surveying, engineering	and	other	related	professional	activities.

• Aerial	v ideo	and/or	photography	for	public	and/or	private	use	including	television,	pu blic	events,	cinematography	and newsgathering

.

• Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the	owners	or	local	government authority.

• Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not	limited	to	electrical	power lines,	wind	turbines	and	cell	towers.

• Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	operat ions	in	cases	of	an	emergency or	natural	disaster	only	when	the	local	authorities	or	government	has	requested	it	by	contract	or	donation.

• Closed	set	motion	picture,	television,	high	speed	and	still	frame	filming	(MPTOM	included	in	this	document)

• The ability	to	offer	training	to	persons	individually	or	belonging	to	both	private	and/or	public	organizations	that	have interests	in	the	use	and	application	of	a	UAS	for	the	purpose	of	the	safe	operation	of	a	UAS	to	enhance	the	safety	of	the National	Airspace System	(NAS)	as	well	as	for	the	protection	of	the	persons	and	property.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	UAS	under	controlled	conditions	in	the	NAS that	would	be	a)	limited	b)	controlled	c)	predetermined	a nd	d)	will	provide	safety	enhancements	to	the	already	safe	operations	in the	industry	presently	using	conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the Secretary	of	Transportation’s	(the	FAA	Administrator’s)	res ponsibilities	to	“....establish	requirements	for	the	safe	operation	of such	aircraft	systems	in	the	national	airspace	system.”



## P etitioner’s	Contact	Information (14	C.F.R.	§	11.81(a))

The	name	and	address	of	the Petitioner is:

Cranial	Thunder ,	LLC
6920B	Braddock	Rd.	#150 Annandale,	VA	22003

The	point	of	contact	for	purposes	of	this	petition	is:

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

2 Mr.	Brett	M.	Thorson Cranial	Thunder,	LLC
6920B	Braddock	Rd.	#150 Annandale,	VA	22003

F AA 333Exemption@CranialThunder.com



## A ircraft	and	Equivalent	Level	of	Safety
The	operational	limitations	proposed	will	provide	for	an	equivalent	or	higher	level	of	safety	because	operations	will	further enhance	the	safety	of	the	persons	and/or	property	using	co nventional	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:

• The	UAS with	payload will	weigh	less	than	55	lbs.

• The	UAS	will	have	a	maximum	op erating	speed	of	no	more	than	100 mph.

• Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	(VO).

• Maximum	flight	time	for	each	operational	flight	will be	20	minutes.	Flights	will	be	terminated	at	25%	battery	power	reserve or	20	minutes	of	flight	time	whichever	occurs	first.

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

• Minimum	crew	for	each	operation will	consist	of	the	UAS	Pilot	and the	Visual	Observer	(VO )

.

• The	UAS	pilot	will	be	the designated	Pilot	in	Command	(PIC)	and	will	take	and	pass all applicable certifications	currently being	approved	by	the	FAA.

• A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight	consisting	of	all	the	days’ production	activities.

• All	flights	will	occur	under	Visual	Flight	R ules	Meteorological	Conditions	(VMC)	only.

• If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP)	of	a	tower	controlled	or uncontrolled	airport

, the	respective	airports	will	be	contacted	advising	them	of	the	est imated	flight	time,	flight	duration, elevation	of	flight	and	other	pertinent	information.

• 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	required	under	the	FOM.	With	the	advanced	permission	of the	FSDO,	operations	at	closer	range	may	be	approved.

• The	PIC	and	VO	w ill	have	been	trained	in	operation	of	UAS	and	receive	up

- to

- date	information	for	the	particular	UAS	to	be operated.

• T he	PIC	and	VO	will	be	able	to	communicate	by	voice, and/or radio	at	all	times.

• Written	and/or	verbal	permission	and	permits	will	be	obtaine d ,	as	applicable, from	territorial,	state,	county	or	city jurisdictions,	including	law	enforcement,	fire	or	other	appropriate	governmental	agencies.

• If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will	have	the	capab ility	to	return
to	a	pre

- determined	location	within	a	designated	location	and	land	autonomously.

• The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or	emergencies.



## UAS	platforms

Cranial	Thunder,	LLC	is petitioning	for	exemption	to	enable Cranial	Thunder LLC	to	operate the	following UAS:

• Aer yon	Labs	Sky	Ranger	multi

- rotor

• Zero

- Tech	High	One	quadcopter

• DJI	Phantom	3	Professional

• DJI	Phantom	3

• DJI	Inspire	1	Pro

• DJI	Matrice	100

• DJI	Spreading	Wings	S1000+

• DJI	Spreading	Wings	S900

• Yuneec	H920	Tornado

• Yuneec	Q500

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

3 • 3D	Robotics	X8

• 3D R obotics Solo

• 3D R obotics Aero

• 3D R obotics IRIS+

• Aero

- X

• AEE	F100

• AEE	F50

• AEE Toruk	AP11

• AEE	Toruk	AP10	Pro

• AEE	Toruk	AP9

• AEE	Toruk	AP12

• Draganflyer	Guardian

• Draganflyer	X4

- P

• Draganflyer	X4

- ES

• Draganflyer	Commander

Cranial	Thunder,	LLC	will	operate	t hese UAS with	a	total	weight

, including	payload, of	less	than	5 5	lbs

. within	line	of	sight	within	a closed	off	and	predetermined	area	owned	and/operated	by	the	property	representative. Each	system	also	has	the	failsafe function	of	the	autopilot	system,	which	means if communication	between	the	Main	Controller	and	the receiv er of	the UAS is	lost;
the UAS will	automatically	trigger a	r eturn	to a	predetermined	position	within	the	safe	operating	area and	will	land	safely.



## Public	Interest

Given	the	small	size	of	the	UAS	and	the	controlled	environment	provided,	the	proposed	operations	will	adhere	to	the	Reform	Ac t’s safety	requirements.	The	approval	of	this	application	presents	no	national	security	issues.	Approval	of	this	exemption	will	a ll ow responsible and	experienced Cranial	Thunder,	LLC	pilots	to	perform	UAS	operations	in	a	safe	manner	as	well	as	train	other s on safe	UAS	operations.		Regarding	the	level	of	safety	surrounding	the	proposed	operations	and	the	public	benefit,	reduction	in

en vironmental	impacts,	including	but	not	limited	to	reduced	emissions	and	noise,	the	grant	of	the	requested	exemption	is	in	the public	interest.	Accordingly	the	applicant	requests	that	the	FAA	grant	the	requested	exemption.

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

4 

## Regulations	from	which	the	exemp tion	is	requested:

14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113	(a)	&	(b) 14	CFR	91.7	(a) 14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.105

14	CFR	91.109 14	CFR	91.119	(c)

14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)

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	l evel	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	authoriz e the	FAA	to	exempt	aircraft	from	the	requirement	for	an	airworthiness	certificate,	upon	considera tion	of	the	size,	weight,	speed, operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular	UAS.	In	all	cases,	an	analysis	of	the se criteria	demonstrates	that	the	UAS	operated	without	an	airworthiness	certificate,	in	the	restri cted	environment	and	under	the conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	rotorcraft)	operating	wit h	an airworthiness	certificate	without	the	restrictions	and	conditions	proposed.

The	UAS	to	be	oper ated	hereunder	is	less	th an	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	aircra ft, 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	si ze,	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	light

- sport	category	aircraft	or	experimental	or	provisionally	certificated	aircraft,	the	operator	must	also display	on	that	aircraft	near	each	entrance	to	the	cabi n,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	than	6 inches	high,	the	words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or	"provisional,"	as	applicable.

Even	though	the	UAS	will	have	no	airworthiness	certificate,	an exemption	will	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	th e	fuselage	in compliance	with	§45.29	(f).

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	a s	“Experimental.”

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

5 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	airc raft that	is	carryi ng	passengers	or	property	for	compensation	or	hire.

An	equivalent	level	of	safety	can	be	achieved	by	current	Regulations	because	the	applicant’s	UAS	do	not	carry	any	pilots	or

passengers or property.	The	risks	attendant	to	the	operation	of	UAS	is	far	les s	than	the	risk	levels	inherent	in	the	commercial activities	outlined	in	14	CFR	61.	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	fo r 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	p erson	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	Rot orcraft Flight	Manual,	approv ed	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	bo ard,	but
because	there	is	no	ro om	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	a pproved rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an	exemption	will	be	needed.	The	PIC	will	take	al l	actions	as	stated	in the	manufacturer	FOM	in	the	pre

- flight	inspection	section,	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.	§91.105:	Flight crewmembers at	stations

Exemption	may	be	required,	the	PIC	may	not	leave	his	station	nor	shall	VO	leave	station	.	In	event	that PIC	or	VO	become

i ncapacitated,	UAS	is	to	automatically	return	to	designated	landing	area,	as outlined	in FOM

.

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	fli ght instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	UAS	and	rem otely	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	ai rcraft via	radio	communications.	The	FAA	has	approved	exemptions	for	flight	tra ining	without	fully	functional	dual	controls	for	a	number of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	equivalent	level	of	safety	provided	by	the	fact	that	nei ther	a	pilot nor	passengers	will	be	carried	in	the	aircraft	and	by	the	si ze	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	operat ed	at	less than	the	minimums	prescribed,	provided	the	pe rson	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	a t altitudes	up	to	400	AGL,	or	not	more	than	200	a bove	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	th at	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

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

6 security	perimeter,	where	buildings	and	people	will	n ot	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	ope rations. Compared	to	flight	operations	with	aircraft	or	rot orcraft	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	conventiona l aircraft	operating	at	or	below	500	AGL.	In	addition,	t he	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	operati ng	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	safety	check	list	and	live	flight	data	monitoring,	confirming	the	altitude	of	th e	launch
site	shown	on	the	GPS	altitude	in dicator	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	w ind 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	25	minutes	of	powered	flight.	To	meet	the 30

- minute reserve	requirement in	14	CFR	§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	locat ion	of	its	proposed	operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in daylight	or	twilight	VFR	conditions	is	reasonable.

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	exemptions.	Operat ing	the	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	i ntended	to alleviate	given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	UAS	flights	to	10	minutes	would	greatly	reduce	th e	utility for	which	the	exemption	will	be	granted.	Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved by	limiting	flights	to 20	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):	Car rying	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	airworthi ness	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	no	more	than	55	lbs.	and	is	operated	without	an	onboard	pilot.	As	such,	there	is	no	ability	or	pl ace	to carry	certification	and	registration	documents	or	to	display	them	on	the	UAS.

An	equi valent	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.

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

7 These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	o f	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	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	cert ificate,	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 usually operating from	no	higher	than	400	feet	AGL.	The	operator	will	ensure	that	the	UAS	is	in	wor king	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	pro vide	the	equivalent	level	of	safety.

An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and	inspections	will	be	performed	in	accordance	with	the	U AS 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	needed.



## Add itional	Information

The applicants’	primary pilot s, Brett	M.	Thorson,	Owner of Cranial	Thunder ,	LLC

, and	Samer	Najia, have been	involved	in the piloting	of	remote	co nt rolled	aircraft	for	more	than 2 years

. Both	applicants hold at	least an	IFR	Private	Pilot	Certificate with complex	and	high	performance	sign	offs. Additionally, Samer	Najia	is	a	commercial	pilot	with	CFI	and	MEI	ratings	working	towards obtaining	his	CFII. Additional	pilots	(also	included	in	the	MPTOM)	are	Zach	Hinkel	ATP	and	Matthew	Ramsey	ASEL.

Both	pilots	are	active	in	the	UAS	community	building	prototype	sy stems,	and	training	others	on	the	use	of	commercial	systems.

T he applicants also have in

- depth	understanding	of	the	capabilities	and	safety	concerns	involved	in	using	this	technology	as	an asset	to	the	community.	Satisfaction	of	criteria	provided	in	Sectio n	333	of	the	Reform	Act	of	2012	provide	more	than	adequate justification	for	the	grant	of	the	requested	exemptions	allowing	the	commercial	operation	of	the	applicant’s	UAS.

Sincerely,

Brett	M.	Thorson ,	Owner

Cranial	Thunder ,	LLC

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

8 

# Motion	Picture	and Television	Operation	Manual
Cranial	Thunder,	LLC
6920B	Braddock	Rd	#150 Annandale,	VA	22003 FAA333Exemption@CranialThunder.com

Revision	Control Page	Revision# Date Initials

___________________________________________________________ ___________

______________________________________________________________________



# Introduction

Purpose This	manual	has	been	developed	by	Cranial	Thunder,	LLC,	in	conjunction	with	an	application	for	a Certificate	of	Waiver	of	Authorization	of	the	provisio ns	of	FAR	91.119	(b)	and	(c)	for	the	purposes of	filming using	Unmanned	Aerial	Systems	(UAS)

. Cranial	Thunder pilots

, and	other	company personnel	when	applicable

, will	comply	with	the	policies,	procedures	and	conditions	of	this manual,	whenever	motion	pict ure	or	television	flight	operations	are	performed	that	require	a
Waiver	of	Authorization	as	mentioned	above.



## Pilot/Operator	Organization

Brett	M.	Thorson

- Pilot
Cranial	Thunder ,	LLC 6920B	Braddock	Rd.	#150 Annandale,	VA	22003



## C.	Persons	Authorized

FAR 91.119	(c)	is	waived	only	with	respect	to	those	persons,	vehicles	and	structures	directly involved	in	the	performance	of	the	actual	filming.	The	certificate	holder	shall	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	if	an	equivalent	level	of	safety can	be	achieved	and	the	Administrator	has	approved	it.	For	example,	an	equivalent	level	of	safety may	be	determined	by	an	Aviation	Safe ty	Inspectors’	(ASI)	evaluation	of	the	filming	production area	to	note	terrain	features,	obstructions,	buildings,	etc.	Such	barriers	may	protect nonparticipating	persons	(observers,	the	public,	news	media,	etc.)	from	debris	in	the	event	of	an
accident.



## Are a	of	Operations
Cranial	Thunder 's	approved	area	of	operations	will	be	the	continental	U nited	States,	Alaska	and
Hawaii.



## Plan	of	Activities At	least	three	(3)	days	prior	to	any	scheduled	filming, Cranial	Thunder will	submit	a	written	plan
of	activities	to	t he	local	FSDO	having	jurisdiction	over	that	area. The	plan	of	activities	should	include	the	following:

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

9 • Dates	and	times	for	all	flights.

• Name	and	phone	number	of	person	responsible	for	the	filming	production	event.

• Name	and	phone	number	of	person	responsibl e	for	aircraft (UAS)

.

• Make,	model,	and	serial	or	N

- number (or	registration	number	for	UAS) of	aircraft	to	be used	and	type	of	airworthiness	certificate (if	applicable) ,	including	category.

• Name	and	certificate	number	of	pilots	involved	in	the	filming	produ ction	event,	including any	notation	of payload load	or specific	maneuver competency,	if	required.

• A	statement	that	the	waiver	holder	has	obtained	permission	from	property	owners	and/or local	officials	to	conduc t	the	filming	production	event.

• The list	of those	who	gave	permission	must	be	made	available	to	the	inspector	upon request	from	the	waiver	holder.

• Signature	of	waiver	holder	or	representative.

• A	description	of	the	flight	activity	including	maps	or	diagrams	of	any	area,	city,	town, county,	and/or	Sta te	over	which	filming	will	be	conducted	and	the	minimum	altitudes essential	to	accomplish	the	operations.

• The	three	(3)	day	notification	requirement	may	be	waived;	however,	the	operator	should contact	the	FSDO	as	soon	as	possible	with	this	request	and	be	p repared	to	explain	in	detail why	the	three	(3)	day	notification	is	not	practical.



## Permission	to	Operate Before	any	flight	operations	is	conducted	at	less	than	500	feet	under	the	provisions	of	the certificate	of	waiver	and	this	manual,	the	operator	will	obt ain	permission	to	conduct	these operations	from	property	owners	and	local	officials	as	necessary	or	appropriate.	Persons	from whom	permission	ma y	be	required	are	listed	below:

• Property	owners

• Law	enforcement	officials

• Fire	department	officials

• Local,	State	and	Federal	government

• Air	traffic	control

Cranial	Thunder personnel	obtaining	such	permission	will	do	so	in	writing	whenever	practical, however,	verbal	permission	is	acceptable	otherwise.	A	standard	permission	form	is	provided	in Appendix	A

- 3 and	may	be	used	when	obtaining written	permission. Cranial	Thunder personnel will	assure	a	sufficient	number	of	those	forms	are	available	at	the	job	site.	Written	permission forms	will	be	maintained	at	the	job	site	until	flight	operations	are	completed, and	then	turned	into the	chief	pilot	to	be	kept	on	file electronically for	a	minimum	of	six	(6)	months.	These	forms	will	be
made	available for	inspection	by	the	FAA	or	other	official	personnel	upon	request.



## Security Prior	to	any	flight	operation	the	opera tor	will	coordinate	with	appropriate	production	personnel to	devise	a	plan	of	securing	the	area(s)	of	operation	from	all	unauthorized	persons	and	vehicles. Provisions	will	be	made	to	immediately	discontinue	operations	should	the	area(s)	become
unsecured	or for	any	other	reason	in	the	interest	of	safety.

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

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## Briefing	of	Pilot/Production	Personnel Prior	to	the	start	of	any	operation	under	the	provisions	of	this	manual,	the	pilot	in	command	will conduct	a	briefing	of	all	procedures	to	participating	personnel	of	th e	risks	involved,	emergency procedures,	and	safeguards	to	be	followed	during	the	filming	production	event.	Personnel	will also	be	briefed	on	additional	provisions	that	may	be	issued	by	the	FSDO	that	has	geographic responsibility	for	the	operational	area,	i ncluding	the	location	of	boundaries	or	time	limits.	The briefing	shall	cover:

• Authorization	for	motion	picture	and	television	certificate	of	waiver	and	the	attached special	provisions

• Operations	manual

• Plan	of	activities

• Aircraft	parking	and	starting

• Taxi procedures

• Radio	Communications

• Takeoff	procedures

• Aviation	activities	to	be	conducted	during the	filming	production	event

• Approach	and	landing	procedures

• Recall	procedures

• Emergency	procedures

• Risks	to	participating	personnel

• How	to	control	nonparticipat ing	persons



## Certification/Airworthiness

All Cranial	Thunder aircraft	used	in	operations	requiring	a	waiver	of	FAR	91.119	(b)	and	(c) for the	purpose	of	filming	will	be	properly	registered	and	exempted	from	airworthiness	requirements according	to Cranial	Th under	LLC’s FAA 333	exemption.	The	aircraft	will	be	inspected	according to	OEM	guidelines.	Each	aircraft	will	have	a	flight	log	containing	upcoming	scheduled	maintenance and	inspections	and	the	dates	/	time	they	must	be	performed.	A	section	for	discrepanci es	is	also
found	in the	flight	log.	The	pilot	in	command	will	assure	the	aircraft	to	be	flown	is	in	airworthy condition	and	all	required	inspections	and	maintenance	has	been	completed	before	each	flight.



## Pilot	Personnel/Minimum	Requirements

The pilot/operator	shall	establish	and	specify	the	minimum	pilot	requirements.	Minimum requirements	shall	meet	or	exceed	the	following:

• A	current	U.S.	airmen	certificate	with	any	category,	class,	or	type	rating.

• At	least	50	flights	logged	as	PIC	and	at	least 20	flights	logged	as	the PIC	in	the	aircraft	type.

• A	minimum	of	50	flights	in	the	category:	of	aircraft (UAS) to	be	used.

• A	minimum	of	5	flights	in	the	make	an d	model	aircraft (UAS) to	be	used under	the	waiver.



## Communications Prior	to	the	start	of	any	oper ation	covered	by	this	manual,	the	pilot	in	command	will	formulate	a plan	to	provide	communications	capability	to	all	participants	during	the	actual	operation	and filming.	Oral,	visual	or	radio	communications	may	be	used	as	long	as	it	is	effective	and	is	ca pable	of keeping	the	participants	continuously	appraised	of	the	current	status	of	the	operation.

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

11 

## Accident	Notification Should	an	accident	or	incident	requiring	notification	of	the	NTSB	occur,	the	operator	must	comply with	the	notification	requirements	of	N TSB	Part	830.



## Recall/Stop	Procedures Radio	communication,	oral,	visual	or	a	combination	will	be	utilized	to	keep	the	participants continuously	apprised	of	the	current	status	of	operation.



## Special	Provisions The	controls,	procedures,	and	conditions	set	fort h	in	the Cranial	Thunder motion	picture	and television	operations	manual	is	the	primary	assurance	that	persons or	property	within	the	area	of operations will	not	be	jeopardized.	The	aircraft	and	pilots	used	under	this	authorization	and/or waiver	will	only be	those	specified	in	the Cranial	Thunder Motion	Picture	and	Television Operations	Manual	(MPTOM Appendix	A

- 1 )	or	associated	plan	of	activities.	Each	pilot’s	name	and
certificate	number associated	with	an	event shall	appear	on	each	daily	plan	of	activity. All	civil
aircraft ,	UAS and	pilot(s)	participating	in	the	activity	shall	be	available	for	FAA	inspection	before
the	scheduled	event.

Each	pilot

- in

- command	conducting	operations	authorized	under	this	certificate	understands	the conditions	of	issuance,	and that	it	constitutes	a	waiver	of	FAR 91.119	(b)	and	(c).	(See Appendix	A

5 )

T akeoff	and	landing	areas	will	be	protected	in	a	manner	t hat	will prevent	unauthorized	persons from	entering	the	takeoff	and	landing	area at	all	times

.

Cranial	Thunder will	ensure that	participating	persons	involved	in	the	operations	are	thoroughly briefed	on	special	procedures,	communication,	emergency	procedures,	and	on	the	provisions	of
the	aut horization	and/or	waiver	before beginning	the	activities.	No	person	may	participate	in any event	unless	that person	has	received	a	briefing	on	the	provisions	of	the	waiver.



# Company	Organization

Chief	Pilot Duties	and	Responsibilities:

• Final	word	in	the	formulation	of	policy and	procedures	concerning	this manual.

• Act	as	liaison	between Crani al	Thunder and	the	FAA	on	matter	concerning	this	manual.

• Assure	that	each	approved	pilot	is	issued	a	copy	of	this	manual	and	obtain	a signed statement	from	each	that	they	have	read	and	understand	its	contents.

• Maintain	a	current	copy	of	this	manual	at	the	main	base	of	operations	for Cranial	Thunder

.

• Responsible	for	assuring	that	all	revisions	to	this	manual	are	distributed	and	processed properly.

• Must	approve	or	disapprove	each	proposed	job	or	operation	performe d	by Cranial	Thunder under	the	provisions	of	this	manual.

• Assume	the	responsibilities	of	pilot	in	command	when	acting	as	such.

• The	chief	pilot	may	delegate	functions	to	other	personnel	but	retains responsibility.

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

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## Pilot	in	Command Duties	and	Responsibilitie s:

• Assure	that	aircraft	to	be	flown	is	in	airworthy	condition	and	all	inspections	and	required maintenance	have	been	performed	as	per	appropriate	FAR's.

• Acquire	permission	from	the	chief	pilot	before	any	operation	under	the	provisions	of	this
manual.

• Be	ve ry	knowledgeable	of	the	contents	of	this	manual	and	abide	by	the	procedures,	policies
and	conditions	contained	herein.

• Coordinate	with	movie	and	television	personnel	to	formulate	plans,	routes,	locations,	etc. with	safety	of	all	persons	involved	in	the	pri mary	concern.

• Maintain	their	copy	of	this	manual	in	current	condition	and	have	it	on	site	at	any	job	or operation	requiring	the	waiver.

• The	pilot	in	command	may	delegate	functions	to	other	personnel,	but	retains	responsibility.



# Appendix	A

- 1

List	of	Approve d	Pilots

Chief	Pilot
Name	: Brett	Thorson Certificate	Number	: 3140335
Grade	:	Private	ASEL	Instrument
Medical	Class: Third Class (Renewing	01/2016) Contact	Email:	FAA333Exemption@CranialThunder.com

Pilots
Name	: Samer	Najia Certificate	Number	: 2520562 Grade	: Commercial	AMEL	Instrument	Airplane,	CFI,	MEI Medical	Class/Date	: 3 rd 

## (Renewing	06/ 2016 )
Contact Email : FAA333Exemption@CranialThunder.com

Name	: Zachary	Lee	Hinkel Certificate	Number	: 2833694 Grade	: ATP Medical	Class/ Date	: 1 st 

## June	29,	201 5
Contact : drivintin@gmail.com

Name	:	Matthew	Ramsey Certificate	Number:	3256580
Grade:	Private	ASEL Medical	Class	/	Date	:	3 rd



## - 2/6/2014	(Renewing	01/2016) Contact	:	matt@airthunderbolt.com

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

13 

# Appendix	A

- 2

List of	Approved	Aircraft

Make / Model /	Registration	Number Will	be	updated	as	approved	under	FAA	Part	333	Exemption	and	acquisition



# Appendix	A

- 3

Cranial	Thunder ,	LLC



## Permission	Acquisition	Form In	signing	this	form,	I	am	giving	the	pilots	of Cranial	Thunder

, LLC	Permission	to	operate	their aircraft	at	less	than	500	feet	from	property,	or	in	some	jurisdiction	in	which	I	am	responsible	for or	affiliated	with,	for	the	purpose	of	film	or	television	production.

Name: Title: Basis	of	Authority	to	Grant	Permission:
Location: Date	of	Operation: Signature

Date Cranial	Thunder Representative	Receiving	Permission :



# Appendix	A

- 4

Revision	Letter Rev#	Section	Page	Action	Remarks	Initials
R

- R emove	and	Replace
D

- Delete	and	Destroy
N

- Insert	New	Page

Manual	Serial#
Is sued	To Revised	By
Date This	form	must	be	returned	to	the	Chief	Pilot	no	later	tha n	_____________________________



# Appendix	A

- 5

Use	form	7711

- 2	Application	for	Certificate	of	Wavier	or	Authorization	at http://www.faa.gov/documentlibrary/media/form/faa7711

- 2.pdf

## Cranial	Thunder,	LLC Petition	for	Exemption	Filed	under	Section	333	&	MPTOM

14