1 Pappas, Rob (FAA)

From: Brian Streem <brian@dreaminghigher.com> Sent: Tuesday, October 07, 2014 6:26 PM To: Troutman, Jake (FAA) Cc: Matt Levinson; Gregory Walden; Michael Drobac; Burton Brink; Jeff Brink; Pappas, Rob (FAA) Subject: AeroCine GOM and Revisions Attachments: Aerocine GOM (10.7.14) v5.pdf; AeroCine Technical Manual v2.pdf

Hey Jake,

Hope all is well. I am now officially submitting Aero Cine's GOM and technical manual. The document was created by Jeff Brink - our Di rector of Flight Operati ons, Burt Brink - our Agent of Service, and revised by Gregory Walden of Akin Group. All have been cc'ed here.

Please note, we would also like to change our letter of exempti on in section 5, bullet point 10:

AeroCine employs FAA licensed helicopter pilot( s) and conducts a regimented training program;

To:

AeroCine employs qualified UAV pilots in accordance with the PIC/PAC Qualifications outlined in the GOM including EuroUSC certified pilo t and 2008 3D Heli Masters "Fli ght to Music" World Champion, Oscar Ohlson.

Lastly, we would like to revise this portion of the letter:

C. 14 C.F.R. § 61.113: Private Pilo t Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. AeroCine can achieve an equivalent level of sa fety as achieved by current Regulations because AeroCine’s UASs do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though Ae roCine’s pilot vetting and training programs will. Further, private pilot license es will operate AeroCine’s UASs with the same skill. Further, the risks attendant to the operation of AeroCine’s UASs is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, a llowing AeroCine to operate its UASs with a private pilot as the pilot in control will exceed current safety levels in re lation to 14 C.F.R. §61.113 (a) & (b).

To become this:

C. 14 C.F.R. § 61.113: Private Pilo t Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. AeroCine can achieve an equivalent level of sa fety as achieved by current Regulations because AeroCine’s UASs do not carry any pilots or passengers . Further, while we see some value in the items taught in a private pilot ground school, there is no co rrelation between fixed manne d aircraft flying skills2 and flying a UAS. AeroCine's pilot vetting system w ill ensure only pilots of sufficient skill will operate our UASs. Further, the risks attendant to the operation of AeroCine’s UASs is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing AeroCine to operate its UASs with a PAC outlined in the GOM will exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

Jake, please advise if I should s ubmit these changes to th e docket or if this email is sufficient.

Please note that our GOM is PRIVA TE AND CONFIDENTIAL information. Also attached is our Ae roCine Technical Manual.

Feel free to get in touch with me anytime either my email or cell.

Thank you and I look forward to hearing back from you soon.

Brian Streem

-- Co-Founder, CEO AeroCine 201.317.8784 www.dreaminghigher.com @aerocine