Travis Filing, President Airborne Video, Inc., T: 1-402-601-1022 travis@transformationmarketing.com January 8, 2016
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave.,SE Washington, DC 20590
Re: Exemption Request under Section 333 ofthe FAA Reform Act, Part 11 ofthe 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:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, and using Upward Aerial, ExemptionNumber 11254, as precedent, Airborne Video, Inc., operator ofSmall 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 ofits sUASs, so long as such operations are conducted within andunderthe conditions outlined herein or as maybe establishedbythe FAA as required by Section 333.
As described more fully below, the requested exemption wouldpermit the operation ofsmall, unmanned andrelatively inexpensive sUAS under controlled conditions inthe NAS that is 1) limited, 2) predetermined, and 3) controlled as to access. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333( c) ofthe ReformAct.The name and address ofthe 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© ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certainunmanned aircraft systems may operate safely inthe national airspace system (NAS) before completion ofthe rulemaking requiredunder Section 332 ofthe ReformAct. In making this determination, the Secretary is required to determine which types ofsUASs do not create a hazard to users ofthe NAS orthe public orpose a threat to national securityin light ofthe following:
"The UAS's size, weight, speed, and operational capability: Operation ofthe UAS in close proximity to airports andpopulated areas; and, Operation ofthe UAS withinvisual line ofsight ofthe operator."

ReformAct§ 333(a).Lastly, ifthe Secretary determines that such vehicles "may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." Id. § 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 ofthe Act, that includes sUASs, from the requirementthat all civil aircraft musthave a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribedunder subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption inthe 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 ofno more than 87 knots and have the capability to hover, andmove in the vertical and horizontal plane simultaneously. They will be operated only in line ofsight and will be operated more than 500 frompeople otherthan the PIC and the VO and othernecessarypersonnel, and ifnearer to othernon-essential people, then operated only within a predetermined and closed offproperty areaunder the permission ofthe propertyrepresentative. Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system or the public" as perthe Reform Act Section 333 (b).
Given the small size ofthe sUASs involved and when operated for the purpose of closed set motionpicture and television filing and production, then in the restricted sterile environment within which they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofSUASS to commence immediately. Also due to the size ofthe SUASS and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; the strong equivalent level ofsafety 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 ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfullyrequests that the FAA grant the requested exemption without delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe 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 evenhigher level ofsafety ofoperations thanunder the current regulatory structure because the proposed operations are conducted on closed offpropertyunder the permission ofthe property owner orproperty 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 ofsight ofa pilot and/or observer.
3. Maximumtotal flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% batterypowerreserve should that occur priorto the 30 minute limit.
4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than 200 feet above an elevated platformfrom which filming is planned. Ifa structure being surveyed or photographed has a height which exceeds 400 feet AGL, the UAS will not exceed 100' inheight above the highestpoint on that structure.
5. Minimumcrew for each operation will consist ofthe sUAS Pilot, and the Visual Observer.

6

. sUAS Pilotwill be Pilot in Command (PIC). Ifthe PIC deems another operatorto be qualified with the necessary skills to be PIC, that person can also be designated as PIC provided he or she has a minimum of40 hours of flight time with the sUAS or otherwise demonstrates competence and skill inproperly avoidinghazards and interminating flight when unexpected hazards arise.

### 7. Flights will be operated at a lateral distance ofat least 100 feet from any inhabited structures, buildings, vehicles, vessels, orpeople not associated with the operation or who have not signed a waiver in advance ofthe 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 ofthe flight within the boundaries of the safetyperimeterbe present for this briefing.
9. The operatorwill file when applicable, an FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the Flight Standards District Office ("FSDO").
10. The operator will obtain the consent ofall 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 ofsafety determination. Withthe advanced permission of the relevant FSDO, operations at closerrange can be approved.
11. Pilot and observer will have been trained in operation ofUAS 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/ortext.
14. Written and/or oral permission from the relevant propertyholders or propertyrepresentatives will be obtained.
15. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.
16. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have the capabilityto return to apre-determined location within the Security Perimeter and land autonomously.

### 17. The sUAS will have the capabilityto 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 powerrecommended by the manufacturer ifgreater.
20

. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA.). All operations will be conducted in accordance with an ATOissued COA. The exemption holder will apply for a new or amended COA ifit intends to conduct operations that cannotbe conductedunder the terms ofaCOA.
21. All aircraft operated in accordance with this exemption willbe 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 ofthe UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement officialuponrequest.
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 bythe PIC from any moving device or vehicle.
25. All Flight operations will be conducted at least 500 feet from all nonparticipatingpersons, vessels, vehicles, and structures unless:
a. Barriers or structures are presentthat sufficientlyprotect nonparticipating persons from the UA and/or debris inthe event ofan accident. The operator will ensure that nonparticipatingpersonsremainunder such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations will cease immediately in a manner ensuring the safety ofnonparticipating persons; and, b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does notpresent an undue hazard.
The PIC, VO, operatortrainees or essential persons will not be considered nonparticipatingpersons underthis exemption.
26. All operations will be conducted overprivate 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 ofthe operational area as defined bythe applicable C.A. willbe 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 operatorwill have a motionpicture and television operations manual (MPTOM) as documented in this grant ofexemption.
29. At least 3 days before aerial filming, the operator ofthe UAS affectedby this exemption will submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) withjurisdictionoverthe area of proposed filming. Itis understoodthat the 3-daynotification maybe waived with the concurrence ofthe FSDO. The plan ofactivities will include at least the following:
a. Dates and times for all flights; b. Name andphone number ofthe operator for the UAS aerial filming conductedunderthe grant ofexemption;
c. Name andphone number ofthe personresponsible for the onscene operation ofthe UAS; d. Make, model, and serial orN-Number ofthe UAS to beused;filming; e. Name and certificate number ofUAS PIC's involved inthe aerial
f. A statement that the operator has obtainedpermission from property owners and/or local officials to conductthe filming production event; the list ofthose who gave permission will be made available to the inspectorupon request; g. Signature ofexemption holder orrepresentative; and h. A description ofthe flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming willbe conducted and the altitudes essential to accomplish the operation.
30. Flight operations will be conducted closerthan 500 feet from participating persons consenting to be involved and necessary for the filming production, only as specified in the exemptionholder's MPTOM.
Unless otherwise specified in a grant ofexemption, 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 ofairworthiness certificates as required byFAR §91.203(a)(l). Giventhe size and limited operating area associated withthe aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe ReformAct. The Federal Aviation Act (49 U.S.C. §44701(±)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated
areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment andunder the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) 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 pilotnorpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored byboththe operator and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation as is now done with conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motionpicture and television production, provide a greater degree ofsafety 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 ofthese same criteria demonstrates that there is no credible threat to national securityposed bythe UAS, due to its size, speed ofoperation, location of operation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.
14 C.F.R. § 45.23(b). Marking oftheAircraft
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 orexperimental
orprovisionally certificated aircraft, the operatormust also display on that aircraft
near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," lightsport,""experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemptionmay be needed as the UAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Giventhe size ofthe SUAS, twoinch lettering will be impossible. The word "Experimental" will beplaced onthe fuselage in compliance with §45.29(±).
The equivalent level ofsafety will be provided by having the SUAS marked onits fuselage as requiredby §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 regulationto 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 orpassengers, the proposed operations canachieve the equivalent level ofsafety ofcurrent operations byrequiring the PIC operating the aircraft to be competent in operating the sUAS and in avoiding hazards to safety andbyrequiring the PIC to hold either an airline transport, commercial, private, recreational, or sportpilot certificate, with a current FAA airmen medical certificate or a valid U.S. driver's license. The area ofoperation 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 FAAregulatory standard will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and
use ofsafety check lists priorto each flight, an equivalent level ofsafety 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 orRotorcraft Flight Manual is not requiredby §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, andplacards, 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 onthe aircraft, not onlybecause there is no pilot on board, butbecause there is no room or capacity to carry such item on the aircraft. The equivalent level ofsafety will be maintainedbykeeping the flight manual at the ground control pointwhere the pilot flying the sUAS will have immediate
access to it. The FAAhas issued the following exemptions to this regulation: ExemptionNos. 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 offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take allactions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.

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 instructionunless that aircraft has fully functioning dual controls. sUASs and remotelypiloted aircraft, bytheir design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft viaradio communications. The FAAhas approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See ExemptionNos. 5778K & 9862A. The equivalent level ofsafety is providedbythe fact that neither a pilotnorpassengers will be carried in the aircraft andbythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with anyroute or altitudes prescribed for helicopters bythe 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, ornotmore than 200 feet above an elevatedplatform from which filming is planned, an exemptionmay beneeded 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 orphotograph a structure whose height exceeds 400 feet AGL, the UAS will notbe operatedmore than 100 feet above the highest point on the structure. Itwill however be operated in a restricted area with securityperimeter, where buildings andpeople will notbe exposed to operations without theirpre-obtained consent.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight willbetaken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants inthe filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraft weighting far more than the maximum 55 pounds proposed herein and the lack offlammable fuel, anyrisk associated withthese operations is far less thanthose presentlypresented with conventional aircraft operating at orbelow 500 feet AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separationbetween these smallUAS operations and the operations ofconventional aircraft thatmust comply with Section 91.119.
14 C.F.R. §91.121 Altimeter Settings
This regulationrequires each person operating an aircraft to maintain cruising altitude byreference to an altimeter that is set "

... to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may nothave a barometric altimeter, but instead a GPS altitude read out, an exemption maybe needed. An equivalent level ofsafety will be achievedbythe operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.
14 C.F.R. § 91.15l(a): Fuel Requirements for Flight in VFRConditions
Section 91.151(a) prohibits an individual from beginning "a flight in an airplane underVFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes;
or (2) Atnight, to fly after that for at least 45 minutes."
The batterypowering the sUAS provides approximately 30 minutes ofpowered flight. To meet the 30 minute reserve requirement in 14 C.F.R. §91.151, sUAS flights would be limitedto approximately 10 minutes in length. Giventhe limitations onthe UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight
or twilight VFRconditions is reasonable. Applicantbelieves that an exemption from 14 C.F.R. §91.151(a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporationto operate without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where onlypeople andproperty owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe 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 ofsafety canbe achieved bylimiting flights to 30 minutes or 25% ofbatterypower- 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 regulationprovides 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 personmay operate a civil aircraft unless the airworthiness certificate requiredbyparagraph (a) ofthis 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 orcrew.
The UAS fully loaded weighs no more than 55 pounds and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground controlpoint where the pilotflying 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 ofother 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 subpartE ofthis part and shall between required inspections, except as provided in paragraph © ofthis section, have discrepanciesrepaired as prescribed inpart 43 ofthis chapter

... ," and others shall inspect or maintain the aircraft in compliance with Part 43.
Giventhat these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance willbe accomplished bythe operatorpursuantto the flight manual and operating handbook. An equivalent level ofsafetywill be achieved because these small SUASS are very limited in size and will carry a small payload and operate only in restricted areas for limitedperiods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operatorwill ensure that the UAS is in working orderpriorto initiating flight, performrequired maintenance, and keep a log ofanymaintenance performed. Moreover, the operator is the personmost familiar withthe aircraft andbest suited to maintain the aircraft in an airworthy conditionto provide the equivalent level of safety. 14 C.P.R. 91.7(a). An equivalent level ofsafetywill be achievedbecause maintenance and inspections will beperformed in accordance with the UAS Manufacturer's Manual, as referenced inthe Aircraft Operations Manual. As provided in the Operations Manual, the operatorwill ensure that the sUAS is in working order prior to initiating flight and will performrequired maintenance needed.
Additional Views and Information

The applicant conducts marketing efforts for businesses and companies some of whom demand the use ofphotography from elevations above ground level. The applicant also provides services to individuals and families who wish to obtain videos ofweddings and other family affairs. While it seems many videography companies already film and sell their aerial videography withoutbenefit 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, therebybybenefitting not only the local economy, but also bydemonstrating how to go about safe storage and operation ofequipmentunder specific and safe PAA laws.

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication inthe 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 inmotion picture, television, and commercial videography operations. Approval ofexemptions allowing commercial operations ofsUASs in the film industry will enhance safetybyreducing risk. Conventional film operations, using jetorpistonpower aircraft, operate at extremely low altitudesjustfeet from the subject being filmed and in extreme proximityto people and structures, and presentthe risks associated with vehicles that weigh in the neighborhood of4,000 pounds, carrying large amounts of jetA or other fuel (140 gallons forjet helicopters.) Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 pounds and powered bybatteries eliminates virtually all ofthat riskgiven the reduced mass and lack ofcombustible fuel carried onboard. The sUAS is carried to the film set. The sUAS will carryno passengers or crew and, therefore, will not expose themto the risks associated with manned aircraft flights.
The operation ofsmall SUASS, weighting less than 55 pounds, conducted inthe strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 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 overprivate orcontrolled access property with the property representative or owner's prior consent and knowledge. Filming will be ofpeople who have also consented to being filmed or otherwise have agreed to be in the
area where filming will take place. All flights will occurin accordance with any state orlocal laws regarding privacy.
Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012-- size, weight, speed, operating capabilities, proximity to airports andpopulated
areas and operation within visual line ofsight and national security

- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS in the motion picture, television, and commercial videography industry.Travis g Airborne Video, Inc. President and Lead UAS Operator