West Chambless 

T: +1 404 219 7843 

west@soaringcinema.com

August 17, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 21, 14 C.F.R. 45.23 (b), 14 C.F.R. 61.113 (a) & (b),

14 C.F.R. 91.7 (a), 14 C.F.R. 91.9 (b) (2), 14 C.F.R. 91.103 (b), 14 C.F.R. 91.109, 14 

C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151 (a), 14 C.F.R. 91.203 (a) & (b), 14 

C.F.R. 91.405 (a), 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a) (2), 14 C.F.R. 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 11, Soaring Cinema LLC, operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial videography and photography for the 

motion picture, television and commercial videography industry, surveying for 

development, agriculture inspection & aerial mapping, hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

its sUASs 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. 

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

of small, unmanned and relatively inexpensive sUASs under controlled conditions in 

the National Airspace System (NAS) that are 1) limited 2) predetermined 

3) controlled as to access. 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. 

The name and address of the applicant is: 

Soaring Cinema LLC 

ATTN: West Chambless 

Address: 1045 Kentucky Avenue NE

 Atlanta, Georgia 30306

Ph: 404-219-7843

Email: west@soaringcinema.com 

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Regulations from which the exemption is requested: 

14 C.F.R. 21 Subpart H

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.103 (b) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151 (a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. 409 (a) (2) 

14 C.F.R. 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 NAS before completion of the rulemaking required under Section 333 of the 

Reform Act. In making this determination, the Secretary is required to determine which 

types of UASs 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 UAS’s size, weight, speed and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line-of-sight of the operator.

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). 

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 sUASs, 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. § 44711 (a), 49 U.S.C. § 44704, 14 C.F.R. § 91.203 (a) (1). 

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Soaring Cinema's sUASs are rotorcraft, weighing 50 or fewer pounds (lbs.) including 

payload. They operate, under normal conditions, at a speed of no more than 40 knots and 

have the capability to hover and move in the vertical and horizontal plane simultaneously. 

They will operate only in line-of-sight and will operate only within a predetermined and 

closed off property area under the permission of the property representative. Such 

operations will insure that the sUAS will “not create a hazard to users of the national 

airspace system or the public” as per the Reform Act Section 333 (b). 

All of our sUAS aircraft are professionally assembled by Quadrocopter LLC

(www.quadrocopter.com). They all use the Cinestar 8 airframe manufactured by FreeFly 

Systems which is a multi-rotor octocopter made mostly of carbon fiber with small 

amounts of plastic and uses both steel and aluminum fasteners. The airframes of our 

copters vary slightly in size depending on the length of boom arms, propellers and legs. 

The minimum width/diameter of our copters is 113.0 centimeters and the maximum is 

141.0 centimeters. The minimum height is 45.0 centimeters and the maximum is 50.8 

centimeters. All of our sUAS aircraft use flight control boards, navigational control 

boards, power distribution boards and GPS systems manufactured by MikroKopter 

(www.mikrokopter.de). All MikroKopter hardware is mounted exactly the same in each 

sUAS aircraft and each set of sUAS hardware is programmed according to specifications 

set by MikroKopter and Quadrocopter using MikroKopter software. For control of the 

sUAS aircraft, we employ radio systems manufactured by Graupner (www.graupner.de) 

that utilize the 2.4 GHz frequency band and provide telemetry back to the operator 

detailing important status readings/notifications/warnings. All of our sUAS aircraft weigh 

between 9 to 10 pounds (flight ready) and have a maximum payload of 15 pounds. 

Therefore, the maximum weight at which any of our sUAS aircraft could be flying is 25

pounds. The payload we carry is a camera gimbal with a camera mounted that is used for 

filming. A camera gimbal is a mount for cameras that allows remote control of pan and 

tilt that is independent of the sUAS movement. The camera gimbals operate remotely 

using the 2.4 GHz frequency band and also transmit a video signal on the 5.8 GHz 

frequency band to the Gimbal Operator (not the sUAS Operator). 

Our sUAS aircrafts have a maximum speed of 45mph (roughly 40 knots). We have set 

lower limits for our maximum speeds depending on payload: 40mph for payloads of 10 

pounds or less, 35mph for any payloads higher than 10 pounds. Since our sUAS aircrafts

are helicopters, they can hover in the air so they have a minimum airspeed of zero. Most 

operation of the sUAS aircraft will require speeds between 0 and 25mph and faster 

speeds will only be used when operating in wide-open areas with no obstacles. 

Radio control of the sUAS aircraft operates using the 2.4 GHz frequency band. Radio 

control of the gimbal operates using the 2.4 GHz frequency band. Video transmission 

from the gimbal operates using the 5.8 GHz frequency band. 

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Given the small size of the sUASs 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 of UASs to commence immediately. Also due 

to the size of the sUASs and the restricted areas in which the relevant sUASs will 

operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the 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 sUASs for movie and commercial videography operations, the granting of the 

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 for

operations under the current regulatory structure because the proposed operations are 

conducted on closed off property with restricted access and used with the permission of 

the property owner or property representative. 

Our normal operations will be outside of five (5) miles from any airport. If we are asked 

to operate within five (5) miles of an airport we will contact the airport's manager and 

control tower with all flight plans, as well as the FAA through our normal filing of a 

Form 7711-1 (or its equivalent) with the appropriate Flight Standards District Office 

(FSDO). Only upon approval of our flight plans from all entities will we agree to, and 

conduct, any operation within five (5) miles of an airport. 

These limitations and conditions to which Soaring Cinema LLC agrees to be bound 

when conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh no more than 50 lbs.

2. Flights will be operated within line-of-sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will

be terminated at 30% battery power reserve should that occur prior to the 20 minute

limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or not more than

200 feet above an elevated platform from which filming is planned. If a structure being

filmed or photographed has a height which exceeds 400 feet AGL, the sUAS will not

exceed 100 feet in height above the highest point on that structure.

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual

Observer.

6. sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 40 hours

of flight time with the specific sUAS equipment Soaring Cinema LLC operates. The

experience of the PIC will be certified by Soaring Cinema LLC through background

checks and, if necessary, testing. The PIC will also have passed the FAA Airman

Knowledge Test for Private Pilots (Test Code: PAR or PRH). Soaring Cinema LLC

will maintain flight logs of all PICs it employs and provide full transparency to the

FAA regarding the logs and records of these PICs.

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7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited

structures, buildings, vehicles, vessels or people not associated with the operation or

who have not signed a waiver in advance of the operation.

8. A briefing will be conducted in regard to the planned sUAS operations prior to each

day’s production activities. It will be mandatory that all personnel involved with the

operational duties of the flight within the boundaries of the safety perimeter be present

for this briefing.

9.

10.

The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the

requested exemption, with the appropriate local FSDO.

The operator will obtain the consent of all persons involved in the filming and ensure that

only consenting persons will be allowed within 100 feet of the flight operation, and this

radius may be reduced to 30 feet based upon an equivalent level of safety determination.

With the advanced permission of the relevant FSDO, operations at closer range can be

approved.

11. PIC and Visual Observer will be trained in the operation of the specific sUAS

equipment used by Soaring Cinema LLC and will receive up-to-date information on

the particular sUAS to be operated.

12. The PIC designated for any operation will have at least a Class 2 medical certificate.

13. Visual Observer and PIC will, at all times, be able to communicate by voice,

radio and/or text.

14.

15.

16. If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will

have the capability to return to a pre-determined location within the Security Perimeter

and land autonomously.

17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles,

weather or emergencies.

Written and/or oral permission from the relevant property holders or property

representatives will be obtained.

All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire or other appropriate

governmental agencies.

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 sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS 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. 

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The sUAS to be operated hereunder is 50 lbs. or less fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the PIC and will operate 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. These safety enhancements, which already 

apply to civil aircraft operated in connection with motion picture and television 

production, 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 a 

reduced threat to national security posed by the sUAS 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 compared to that of standard pilot-operated aircraft. 

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 are 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 

cabin, 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 sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which 

the word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering 

will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer, and others working with the 

sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued the 

following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 

10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations; Pilot 

in Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS 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 

to have no less than 40 hours of flight time with the specific sUAS equipment Soaring 

Cinema LLC operates. The experience of the PIC will be certified by Soaring Cinema 

LLC through background checks and, if necessary, testing. The PIC will also have passed 

the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). 

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6RDULQJ&LQHPD//& will maintain flight logs that conform to FAA specifications of all 

PICs it employs and provide full transparency to the FAA regarding the logs and records 

of these PICs. The PIC designated for any operation will have at least a Class 2 medical 

certificate. The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the sUAS by a PIC meeting the standards of Soaring 

Cinema LLC (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 

61.113 (a) & (b). 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS 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. Currently there are no 

pilot licenses that are specific for sUAS operators and no current FAA sanctioned pilot 

license of any type requires training with and knowledge of sUAS equipment greater 

than the requirements Soaring Cinema LLC uses to certify its PICs. Therefore, the 

requirement of any available FAA sanctioned pilot license to operate a sUAS does not 

make a PIC a more competent operator than one meeting the requirements of Soaring 

Cinema LLC. Our company hopes the FAA develops a new Pilot License specific for 

UAS and sUAS commercial operation, one that sets high standards on the quality of 

pilots and increases the professionalism of our emerging industry. If the FAA does this, 

Soaring Cinema's PICs will be some of the first to file for these licenses. Our company 

would also be happy to work with the FAA to help develop the standards for new 

licenses and any other regulations the FAA is developing for UAS operation.

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 check lists 

prior to each flight (summaries listed below), an equivalent level of safety will be 

provided. Summarized Safety Checklists: 

1. Aircraft: All adjustment points will be checked for tightness; all motors and

props will be inspected; all wiring will be double checked; all systems will be

powered up and checked for errors.

2. Battery: Confirmation will be made that batteries are fully charged and

installed/connected properly.

3. Calibration: Pre-flight motor/gyro calibration followed by confirmation of no

errors with the flight and navigation systems will be performed.

4. Transmitter: Confirm radio transmitter has sufficient charge and is both

working properly and receiving telemetry from the sUAS; confirm all switches

are in pre-flight mode.

5. Surroundings/Flight Area: Conduct one last visual inspection of the take-off

surroundings and area of airspace sUAS will be operating in. Confirm all

people in the surrounding areas are associated with the filming being done.

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6. Take-off Announcement: Before motors are started the PIC will announce to a

designated Representative (person of authority) of the film crew that sUAS is

ready to take-off. Only after the Representative has notified all persons within

the surrounding areas and confirmed to PIC that they have clearance to lift-off,

will the motors be started and the sUAS will conduct its operation.

7. Test Flight: A test flight will be conducted: after any disassembly/reassembly,

after replacement of any motors or flight electronics, after any pre-flight or in

flight equipment errors that occur not resulting from environmental conditions,

very first thing of any commercial operations day before filming begins, if there

are any concerns about environmental conditions and potential issues with the

flight path.

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 sUAS, 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 PIC flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827 and 10700. 

14 C.F.R. § 91.103 (b): Preflight Action

This regulation requires each pilot incommand 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 

including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data before initiation of flight. 

Prior to the first flight of the day, after transport of sUAS aircraft to a different location, 

or if the PIC determines the sUAS equipment is not functioning properly, an inspection of 

the following things will take place by the PIC: 

- All adjustment points on sUAS will be checked for tightness. 

- All stress points will be inspected for signs of damage or distress. 

- All motors and propellers will be inspected. 

- All wiring and connections will be checked. 

- All systems will be powered up and checked for errors. 

- All batteries will be inspected for any damage or signs of distress. 

- Confirmation will be made that batteries are fully charged and installed/connected 

properly. 

8/13
- Confirm radio transmitter: has sufficient charge; that all switches are in pre-flight 

mode; is both working properly and receiving telemetry from the sUAS. 

- Conduct pre-flight motor/gyro calibration followed by confirmation of no errors with 

the flight and navigation systems. 

- Upon completion of all other pre-flight inspection tasks, a test flight will be conducted 

to confirm all systems are working properly and there are no errors or signs of problems 

with operation of the sUAS equipment. 

Once all of these tasks have been successfully completed, the sUAS aircraft will be 

determined airworthy by the PIC. If any of these tasks are not able to be completed, then

the sUAS will not be airworthy until appropriate maintenance is done and the PIC 

successfully completes another pre-flight inspection. 

14 C.F.R. § 91.109: Flight Instruction 

Section 91.109 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. sUASs 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. See Exemption Nos. 5778K & 

9862A. 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 sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 feet AGL or not more than 

200 feet above an elevated platform from which filming is planned, an exemption may be 

needed to allow such operations. As set forth herein, the sUAS will never operate at 

higher than 400 feet AGL with the exception that in circumstances where the sUAS is 

used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS 

will not be operated more than 100 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, speed of the sUAS 

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 

weighing far more than the maximum 50 lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presented with 

conventional aircraft operating at or below 500 AGL in the movie industry. In addition, 

the low-altitude operations of the sUAS will ensure separation between these sUAS 

operations and the operations of conventional aircraft that must comply with Section 

91.119. 

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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 sUAS 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 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 sUAS provides no more than 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would not be 

possible due to the reserve requirement being equal to the maximum flight time. Given 

the limitations on the sUAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer timeframe for flight in daylight or 

twilight 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 sUAS, with less than 

30 minutes of reserve fuel, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed does not lead 

to the type of risks that Section 91.151 (a) was intended to alleviate given the size and 

speed of the sUAS. Additionally, the limitations created by this requirement for sUAS 

flights would essentially make null any 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 30% of battery power— whichever happens first. This restriction would be 

more than adequate to return the sUAS 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. 

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14 C.F.R. § 91.203 (a) & (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 sUAS fully loaded weighs no more than 50 lbs. 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 sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the PIC flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A and 10700. 

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 and inspections 

will be done in accordance with the sUAS Manufacturer's Manual and will be performed 

by employees of Soaring Cinema LLC following the guidelines and practices provided to 

us by the sUAS Manufacturer. An equivalent level of safety will be achieved because 

these sUASs 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 sUAS can land 

immediately and will be operating from no higher than 400 feet AGL. The PIC will 

ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance and keep a log of any maintenance performed. Moreover, the PIC 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. 

11/13
Additional Views and Information 

Our sUAS aircraft consist of Cinestar 8 airframes, MikroKopter electronics (flight, 

power, navigational, and GPS control boards), and Graupner radio control systems. Each 

of these components has their own manual, and these manuals have been submitted with 

this petition. Here is a list of the manuals for your reference: 

- Cinestar_8_Manual.pdf = Airframe 

- Flight_Ctrl_Board_Manual.pdf = MikroKopter Flight Control Board 

- GPS_Board_Manual.pdf = MikroKopter GPS Board 

- Graupner_GR24_Rx_Manual.pdf = Graupner Receiver 

- Graupner_MX20_Tx_Manual.pdf = Graupner Transmitter 

- MikroKopter_Tool_Manual.pdf = MikroKopter software for interfacing with boards 

- MK_Tool_Settings_Manual.pdf = How to program boards with MikroKopter Tool 

- Navigational_Board_Manual.pdf = MikroKopter Navigational Control Board 

- Power_Dist_Board_Manual.pdf = MikroKopter Power Distribution Board 

Soaring Cinema LLC has realized the amazing benefits sUAS equipment can provide to 

the film and television industries. It not only provides new cinematography capabilities 

but also increased safety over current and past practices that used larger and more 

dangerous equipment. Our company wants to have the highest levels of safety and 

professionalism and one thing essential to this is achieving a path to commercial 

licensing with the FAA. We believe this will help reduce unsafe practices, discourage 

improper uses and improve public perception. The commercial manufacture and use of 

sUAS equipment will create more jobs for the United States and help boost the 

economies in many sectors and we want to help the FAA in creating regulations that will 

allow incorporation of UAS devices into our country's airspace for commercial use. 

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: 

14 C.F.R. § 21, subpart H, 14 C.F.R § 45.23 (b), 14 C.F.R. § 61.113 (a) 

& (b), 14 C.F.R. § 91.7 (a), 14 C.F.R. § 91.9 (b)(2), 14 C.F.R. § 91.103 

(b), 14 C.F.R. § 91.109, 14 C.F.R. § 91.119, 14 C.F.R. § 91.121, 14 

C.F.R. § 91.151(a), 14 C.F.R. § 91.203 (a) and (b), 14 C.F.R. § 91.405 

(a), 14 C.F.R. § 91.407 (a)(1), 14 C.F.R. § 91.409 (a)(2), 14 C.F.R. §

91.409 (a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (50 lbs or less) in motion picture, television and 

commercial videography operations.

Privacy 

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

representative or owner’s prior consent and knowledge. Filming will be of people who 

have also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. All flights will occur in accordance with any state or local laws 

regarding privacy. 

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The operation of small UASs, weighting less than 50 lbs., conducted in the strict 

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

of the exemptions requested herein, including exempting the Applicant from the 

requirements of Part 21 and allowing commercial operations. 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 jet or piston power aircraft

operating in close proximity to the ground and people. 

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 - provide more than adequate justification for the 

granting of the requested exemptions allowing commercial operation of Applicant’s 

sUAS equipment in the motion picture, television and commercial videography 

industry, surveying for development, agriculture inspection & aerial mapping. 

Sincerely, 

West Chambless

Soaring Cinema LLC

Owner and Operator 

Approval of exemptions allowing commercial operations of sUASs 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 risks associated with 

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

or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the film 

location. In contrast, a sUAS weighing fewer than 50 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board. The sUAS is carried to the film set. The sUAS will carry no 

passengers or crew and therefore, will not expose them to the risks associated with 

manned aircraft flights. 

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