August 10, 2015

U.S Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act

508 Productions, LLC.

Chris Babiana

Owner

508-507-0415

Federal Aviation Administration:

On behalf of 508 Productions, LLC, (and all other subsidiaries and DBA’s of 508 Productions, LLC.) I would like to formally submit for an exempt ion from part 21, subpart H; and Sections 45.23( b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a) , 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulati ons (14 CFR). This requested exemption would allow 508 Productions, LLC (and all other subsidiaries and DBA’s of 508 Productions, LLC.) to pursue it’s inte rest of unmanned aircraft systems (UAS) for the purpose of aerial videography and phot ography for real estate, lifestyle, corporate, non-profit and all other business relat ed productions requiring low altitude video/photo aerial operations.

508 Productions, LLC (and all other subsid iaries and DBA’s of 508 Productions, LLC.) will operate various small UAS m odels (under 55 lbs), including but not limited to the FreeFly Cinestar8, DJI Inspire 1 and PHANTOM 3, which is comprised of an unmanned aircraft (UA or PHANTOM), an attached camera (or built in camera with DJI Inspire 1 and PHANTOM 3) and a transportable ground

station.

The DJI Inspire 1, DJI Phantom 3 and FreeFly Cinestar8 are battery powered

and have built-in failsafe features which ar e automatically triggered in the event
communication is lost between the UAS and the main controller transmitter and controller. At that time, the UAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can r egain control of flight and land manually.Operating Parameters:

508 Productions, LLC (and all other subsid iaries and DBA’s of 508 Productions, LLC.) will comply with all of the following conditions and limitations:

1) Operations will be limited to the aircraft as described above.

2) The UA will not be flown at an i ndicated airspeed exceeding 30 knots.

3) The UA will be operated at an altit ude of no more than 400 feet above ground level(AGL).

4) The UA will be operated within visual li ne of sight (VLOS) of the Pilot In Command(PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfe r his or her designation for the duration of the flight. The PIC will ensure that the VO can per form the functions prescribed in the operating documents.

6) The operating documents will be acce ssible during UAS operations and made available to the Administrator upon r equest. Any revisions to the operating documents will be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspec tion reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The

Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8) Any UAS maintenance or alterations t hat affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already

covered in the relevant secti ons of the operating documents.10) Follow the UAS manufacturer’s ai rcraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11) Carry out maintenance, inspections, and record keeping requirements, in accordance with the operating document s. Maintenance, inspection, and

alterations will be noted in the aircraft records, including to tal flight hours, description of work accomplished, and t he signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply wit h all manufacturer Safety Bulletins.

13) An authorized person will make an ent ry in the aircraft record of the corrective action taken against discrepanc ies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a sport pilot

certificate and at least a valid US drivers license.

15) The PIC will not oper ate the UAS unless t he PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate

the UAS in a manner cons istent with the operati ng documents, including evasive and emergency maneuvers and mainta ining appropriate distances from people, vessels, vehicles and structures.

16) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conduct ed under visual meteorolog ical conditions (VMC).

17) The UA will not operate within 5 nautical miles of an airport reference point

as denoted on a current FAA- published aeronautical chart.

18) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

19) If a UA loses communications or lo ses its GPS signal, it will return to a predetermined location within the pl anned operating area and land or be

recovered in accordance wit h the operating documents.

20) The PIC will abort a flight in t he event of unpredicted obstacles or emergencies in accordance wit h the operating documents.

21) The PIC will not begin a flight unle ss (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA wit h 30% battery power remaining.

22) The documents required under 14 CF R 91.9 and 91.203 will be available to
the PIC at the Ground Control Station of the UAS any ti me the UAS is operating.These documents will be made available to the Administrator or any law enforcement official upon request.

23) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times.

24) The UAS will not be operat ed by the PIC from any mo ving device or vehicle.

25) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that suffici ently protect nonparticipating persons from the UA and/or debris in the event of an accident. We will ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations mu st cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

26) All operations will be c onducted over private or controlled-access property with permission from the land owner/contro ller or authorized representative.
Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

27) Any incident, accident, or flight oper ation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on t he NTSB Web site: www.ntsb.gov.

If you have questions or need additional in formation, please contact me at babs70111@gmail.com or 508-507-0415

Thank you.

Chris Babiana

Owner 508 Productions, LLC.