Travis Filing, President 

Airborne Video, Inc., 

T: 1-402-601-1022 

travis@transformationmarketing. com 

January 8, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave.,SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 ofthe FAA Reform Act, Part 11 of the 

Federal Aviation Regulations, from 14 C.F.R. 45.23(b);14 C.F.R. Part 21; 14 

C.F.R. 61.113(a) & (b); 14 C.F.R. 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 

91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409 (a)(2); 

91.417 (a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

Reform Act) and 14 C.F.R. Part 11, and using Upward Aerial, Exemption Number 

11254, as precedent, Airborne Video, Inc., operator of Small Unmanned Aircraft 

Systems ("sUASs") equipped to conduct aerial data collection and to conduct 

aerial videography and photography for the motion picture, television, and 

commercial videography industry for closed set filming, 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 sUAS under controlled 

conditions in the NAS that is 1) limited, 2) predetermined, and 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: 

Airborne Video, Inc 

Attn: Travis Filing 

Address: 209 W. 41

h Street, Panama, NE 68419 

Email: travis@transformationmarketing.com 

Ph: 402-601-1022 

Regulations from which the exemption is requested: 

14 C.F.R. Part 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 

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© of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of sUASs 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; and, 

Operation ofthe UAS within visual line of sight ofthe 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." I d. § 3 3 3 ( c) (emphasis 

added). 

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) ofthis 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). 

Airborne Video, Inc.'s sUASs are JDI Phantom 3 rotorcraft, weighting 55 or fewer 

pounds including payload. They operate, under normal conditions at a speed of no 

more than 87 knots and have the capability to hover, and move in the vertical and 

horizontal plane simultaneously. They will be operated only in line of sight and 

will be operated more than 500 from people other than the PIC and the VO and 

other necessary personnel, and if nearer to other non-essential people, then 

operated 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). 

Given the small size of the sUASs involved and when operated for the purpose of 

closed set motion picture and television filing and production, then in 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 SUASS 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 grant 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 

of operations than under the current regulatory structure because the proposed 

operations are conducted on closed off property under the permission of the 

property owner or property representative. 

These limitations and conditions to which Airborne Video, Inc proposes to be 

bound when conducting commercial operations under an FAA issued exemption 

include: 

1. The sUAS will be JDI Phantom 3 rotorcraft which weigh less than 55 

pounds including payload. 

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 30 minutes. 

Flights will be terminated at 25% battery power reserve should that occur 

prior to the 30 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 surveyed or photographed has a height which 

exceeds 400 feet AGL, the UAS will not exceed 100' 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). If the PIC deems another 

operator to be qualified with the necessary skills to be PIC, that person can 

also be designated as PIC provided he or she has a minimum of 40 hours of 

flight time with the sUAS or otherwise demonstrates competence and skill 

in properly avoiding hazards and in terminating flight when unexpected 

hazards arise. 
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. The operator will file when applicable, an FAA Form 7711-1, or its 

equivalent, as modified in light of the requested exemption, with the Flight 

Standards District Office ("FSDO"). 

10. 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. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated. 

12. The observer designated for any operation will have at least a class 2 

medical certificate. 

13. Observer and pilot will at all times be able to communicate by voice, radio, 

and/ or text. 

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

property representatives will be obtained. 

15. 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. 

16. If the sUAS loses communications or loses its GPS signal, the UAS 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 ofunpredicted 

obstacles, weather, or emergencies. 

18. The PIC will abort the flight in the event ofunpredicted obstacles or 

emergencies. 

19. The PIC will not begin a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct 

the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater. 

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA.). All operations will be conducted in accordance with an A TOissued COA. The exemption holder will apply for a new or amended COA 

if it intends to conduct operations that cannot be conducted under the terms 

ofaCOA. 

21. All aircraft operated in accordance with this exemption will be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N-Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings will be as large as practicable. 

22. Documents used by the operator to ensure the safe operation and flight of 

the UAS and any documents required under 14 C.F.R. §§ 91.9 and 91.203 

will be available to the PIC at the Ground Control Station of the UAS any 

time the aircraft 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 give way to all manned aviation operations 

and activities at all times. 

24. The UAS will not be operated by the PIC from any moving device or 

vehicle. 

25. All 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 sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator will ensure that nonparticipating persons 
remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations will cease immediately in a 

manner ensuring the safety of nonparticipating persons; and, 

b. The owner/controller of any vessels, vehicles or structures has 

granted permission for operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption. 

26. All operations will be conducted over private or controlled-access property 

with permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

27. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable C.A. 

will be reported to the FAA's UAS Integration Office (AS-80) within 24 

hours. Accidents will be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

28. The operator will have a motion picture and television operations manual 

(MPTOM) as documented in this grant of exemption. 

29. At least 3 days before aerial filming, the operator of the UAS affected by 

this exemption will submit a written Plan of Activities to the local Flight 

Standards District Office (FSDO) with jurisdiction over the area of 

proposed filming. It is understood that the 3-day notification may be 

waived with the concurrence of the FSDO. The plan of activities will 

include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial 

filming conducted under the grant of exemption; 

c. Name and phone number of the person responsible for the onscene operation of the UAS; 

d. Make, model, and serial or N-Number of the UAS to be used; 
filming; 

e. Name and certificate number ofUAS PIC's involved in the aerial 

f. A statement that the operator has obtained permission from 

property owners and/or local officials to conduct the filming 

production event; the list of those who gave permission will be made 

available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of 

any area, city, town, county, and/or state over which filming will be conducted and 

the altitudes essential to accomplish the operation. 

30. Flight operations will be conducted closer than 500 feet from participating 

persons consenting to be involved and necessary for the filming production, 

only as specified in the exemption holder's MPTOM. 

Unless otherwise specified in a grant of exemption, the UAS, the UAS PIC, and 

the UAS operations will comply with all applicable parts of 14 C.F.R. including, 

but not limited to, parts 45, 47, 61, and 91. 

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)(l). 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(±)) 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 sUAS to be operated hereunder is less than 55 pounds 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 both 
the operator and 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 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 ofthe 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 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 SUAS, twoinch lettering will be impossible. The word "Experimental" will be placed on the 

fuselage in compliance with §45.29(±). 

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

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

with the SUAS will see the identification ofthe UAS as "Experimental." The FAA 

has issued the following exemptions to this regulation to Exemptions Nos. 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 UAS 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 be competent in operating the sUAS and in avoiding 

hazards to safety and by requiring the PIC to hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate, with a current FAA 

airmen medical certificate or a valid U.S. driver's license. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. 

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, 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 JDI Phantom 3 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 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 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: 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 including 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. 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 UAS will never operate at higher than 400 feet 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 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 

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 55 

pounds 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 feet AGL in the movie industry. In addition, the 

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

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. § 91.15l(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 approximately 30 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 C.F.R. §91.151, sUAS 

flights would be limited to approximately 10 minutes in length. Given the 

limitations on the UAS's proposed flight area and the location 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 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 

small 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 intended to alleviate given the size and speed of the small UAS. 
Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility 

for which the exemption will be granted. 

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 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. 

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 no more than 55 pounds 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 pilot 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 © 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 these small 

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 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. 14 C.P.R. 91.7(a). An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS 

Manufacturer's Manual, as referenced in the Aircraft Operations Manual. As 

provided in the Operations Manual, the operator will ensure that the sUAS is in 

working order prior to initiating flight and will perform required maintenance 

needed. 

Additional Views and Information 

The applicant conducts marketing efforts for businesses and companies some of 

whom demand the use of photography from elevations above ground level. The 

applicant also provides services to individuals and families who wish to obtain 

videos of weddings and other family affairs. While it seems many videography 

companies already film and sell their aerial videography without benefit of 

permits, the applicant would like to shown and be an example as to how a safe a 

legal aerial videography company can conduct themselves, thereby by benefitting 

not only the local economy, but also by demonstrating how to go about safe 

storage and operation of equipment under specific and safe P AA laws. 

Pursuant to 14 C.P.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.P.R. §21, subpart H; 

14 C.P.R. 45.23(b); 14 C.P.R.§§ 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.1 03(b); 

91.1 09; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(l); 
91.409(a)(2); 91.409(a)(2) and 91.417(a) & (b) to operate commercially a small 

unmanned aerial vehicle (55 pounds or less) in aerial data collection and in motion 

picture, television, and commercial videography operations. 

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 the risks associated with vehicles that weigh in the neighborhood of 4,000 

pounds, 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 55 pounds 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. 

The operation of small SUASS, weighting less than 55 pounds, 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 turbine helicopters operating in close proximity to the ground and 

people. 

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. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012--

size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security - provide more 

than adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicant's UAS in the motion picture, television, and 

commercial videography industry. 
Travis g 

Airborne Video, Inc. 

President and Lead UAS Operator