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 AeroCine's GOM and technical manual. The document was 

created by Jeff Brink - our Director of Flight Operations, 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 exemption 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 pilot and 2008 3D Heli Masters "Flight 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 Pilot 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 safety 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 AeroCine’s pilot vetting and training programs 

will. Further, private pilot licensees 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, allowing AeroCine to operate its UASs with a private 

pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

To become this: 

C. 14 C.F.R. § 61.113: Private Pilot 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 safety 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 correlation between fixed manned aircraft flying skills 
2

and flying a UAS. AeroCine's pilot vetting system will 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 submit these changes to the docket or if this email is sufficient. 

Please note that our GOM is PRIVATE AND CONFIDENTIAL information. 

Also attached is our AeroCine 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