New World Productions, Inc.

Todd Andrew Gross T: 1-612-338-6448 todd@newworldproductions.net

November 3, 2015
U. S. Department ofTransportation Docket Management System 1200 New Jersey

### Ave., SE Washington, DC 20590 ';/ ''

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Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b):14 CFR Part 21:14 CFR 61.113 (a) & (b); 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)i 91.409 (a) (2):91.417 (a) & {lJl
Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, New World Productions, Inc., operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography and video for the media 

### use, herebyapplies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits 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 permitthe operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements tothe already safe operations. Approval ofthis exemption would therebyenhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.The name and address ofthe applicant is:
New World Productions, Inc. Attn: Todd Andrew Gross Ph: 612-338-6448 Email: todd@newworldproductions.net Address: 1500 Jackson St NE, Suite 402, #181, Minneapolis, MN 55413

1) The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate ofWaiver for Media production videography Regulations from which the exemption is requested:
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 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 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemakingrequired under Section 332 ofthe Reform Act. In makingthis determination, the Secretaryis required to determine which types ofUASs do not create a hazardto users ofthe NAS orthe public orpose a threatto national securityin light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator.Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. §333(c) (emphasis added)
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authorityby its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, thatincludes sUASs, from the requirementthat all civil aircraft musthave a current airworthiness certificate. Applicant interprets this provision to place the duty on the Administratorto not only process applications for exemptions under section 333, butfor the Administratorto craft conditions for the safe operation ofthe UAS, ifit should be determined thatthe conditions set forth herein do notfulfill the statutory requirements for approval.
The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).
New World Productions, Inc. sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, undernormal conditions at a speed ofno more than SO knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line ofsight and will operate only within the sterile area. Such operations will insure thatthe sUAS will "notcreate a hazard to users ofthe national airspace system orthe public. Given the small size ofthe sUASs involved and the restricted sterile environment within which theywill operate, the applicant falls squarelywithin thatzone ofsafety (an equivalentlevel ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofUASs to commence immediately. Also due to the size ofthe UASs 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 in the Federal Aviation Act, as amended; the strong equivalentlevel ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for digital media operations, the grantofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe exemption requested herein apply to civil aircraft thathave the characteristics and that operatewith the limitations listed herein.These limitations and conditions to which New World Productions, Inc. agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55lbs.
2. Flights will be operated within line ofsight ofa pilot and/or observer.
3. Maximum total flight time for each operational flight will be 30 minutes. Flights will beterminated at 25% battery power reserve should that occur priorto the 30-minutelimit.
4. Flights will be operated at an altitude ofno more than 400 feet AGL or, notmore than 200 feet above an elevated platform from which filming is planned. 5. Minimum crewfor each operation will consist ofthe sUAS Pilot, theVisual Observer, and the Camera Operator.
6. The UAS will only operate within a confined "Sterile Area" as defined by best practices requiring the establishment ofa "Security Perimeter" for the flight operations area. 7. Abriefing will be conducted in regard to the planned sUAS operations prior to each day's production activities. Itwill be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeterbe presentfor this briefing. 8. The operatorwill obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius maybereduced to 30 feet based upon an equivalent level ofsafety determination. 9. Pilot and observer will have beentrained in operation ofUAS generally and received up-to-date information on the particular UAS to be operated as required.
10. Observer and pilotwill at all times be able to communicate byvoice and/ortext. 11.Written and/or oral permission from the relevantpropertyholders will be obtained. 12. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 13. Ifthe sUAS loses communications orloses its GPS signal, the UAS will havecapability to return to a pre-determined location within the Security Perimeter and land.
14. The sUAS will have the capabilityto abort a flight in case ofunpredicted obstacles or emergencies.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bytheApplicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalentlevel ofsafety under Part 11 and Section 333 of the Reform Act The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the 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 proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated withoutan airworthiness certificate, in the restricted environmentand underthe conditions proposed will be atleast as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 55 lbs. 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 underthis exemption will be tightly controlled and monitored by both the operator, and underthe requirements and in compliance with local public safety requirements, to provide security for the area ofoperation. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafetyto the public and propertyownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, SubpartH. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the UAS, dueto its size, speed ofoperation, location of operation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.
14C.F.R. § 45.23 

### (b). Marking oftheAircraft
The regulation requires:When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraftor 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 notless than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "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 ofthe sUAV, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalentlevel ofsafety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAVwill see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.
14C.F.R. § 61.113 (a) & 

### (b): Private PilotPrivilegesand Limitations: Pilotin 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 equivalentlevel ofsafety ofcurrentoperations by requiring the PIC operatingthe aircraft to have a private pilot's license ratherthan a commercial pilot's license to operate this small UAS. Unlike a conventional aircraftthatcarries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety provided by the requirements exceeds thatprovided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the presentlevel ofsafety achieved by 14 C.F.R. §61.113 (a) & (b).
14 C.F.R. §91.7(a): Civil aircraftairworthiness. The regulation requires thatno person may operate a civil aircraft unless itis in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standardwill exist for determining airworthiness. Given the size ofthe aircraft and the requirements an equivalent level ofsafety will be provided.
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the AircraftSection 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 notrequired by §21.5 ofthis chapter, unless there is available in the aircraft a currentapproved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
The sUAS, given its size and configuration has no ability orplace 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 capacityto carry such an item on the aircraft.

The equivalentlevel ofsafety will be maintained by keeping the flight manual at the ground control pointwherethe 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, 9565,95658,10167, 10167A, 10602,32827, and 10700.
14C.F.R. § 91.103: Preflightaction 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 notbe provided for the aircraft an exemption will be needed. An equivalentlevel of safety will be provided. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance databefore initiation offlight.
14 C.F.R. §91.109: Flightinstruction: Section 91.103 provides thatno person may operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has ful1y functioning dual controls. sUASs and remotely piloted aircraft, by their design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia 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 ofsafety provided by the fact thatneither a pilotnor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
14C.F.R. §91.119: Minimum safe altitudesSection 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated atless thanthe minimums prescribed, provided the person operating the helicopter complies with any route 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 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UAS will never operate athigher than 400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will notbe exposed to operations withouttheir pre-obtained consent. The equivalentlevel ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the propertyowner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraftweighting far more than the maximum 55lbs. proposedherein and thelack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating ator below 500 AGL in the film and media industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small-UAS operations and the operations ofconventional aircraftthatmust comply with Section 91.119.
14C.F.R. §91.121Altimeter Settings
This regulation requires each person operating an aircraftto maintain cruising altitude by reference 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, butinstead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuantto a Safety Check list, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions 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 thatfor atleast 30 minutes; or (2) At night, to fly after that for atleast45 minutes." The battery poweringthe sUAS provides approximately 40 minutes ofpowered flight. To meetthe 30-minute reserve requirementin 14 CFR §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 ofits proposed operations within apredetermined area, a longer time frame for flight in daylight ornight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operatewithout 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 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 equivalentlevel ofsafety can be achieved by limiting 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 regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and currentairworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so thatitis legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs and is operated withoutan onboard pilot As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS.
An equivalent level ofsafety will be achieved bykeeping these documents atthe ground control pointwhere the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. Arepresentative sample ofother exceptions includes Exemption Nos. 9565, 9665,9789, 9789A, 9797,9797 A, 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 subpartEofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part43. Given thatthese section and Part 43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook from the UASs manufacture. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operatingfrom no higher than 400 feet AGL. As provided in the manufactures manual, the operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.
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Pursuantto 14 C.F.R. Part 11, the following summaryis provided for publication in the Federal Register, should itbe determined thatpublication is needed: Applicant seeks an exemption from the following rules:14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in film and digital media production operations. Approval ofexemptions allowing commercial operations ofsUASs in the digital media industrywill enhance safety by reducing risk. Conventional film operations, usingjetorpiston power aircraft, operate at extremely low altitudesjustfeet from the subjectbeing filmed and in extreme proximityto people and structures; and presentthe risks associated with vehicles thatweigh in the neighborhood of 4,000lbs., carrying large amounts ofjetAor other fuel (140 gallons forjet helicopters). Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthatrisk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the film setand notflown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.The operation ofsmall UASs, weightingless than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalentlevel ofsafety supportingthe grantofthe 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 saferthan conventional operations conducted with turbine helicopters operating in close proximityto the ground and people. Privacy
All flights will occur over private or controlled access propertywith the property 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. The grantofthis exemption requestwill provide improved safety in both day and night operations. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-- size, weight, speed, operating capabilities, proximityto airports and populated 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 film and digital media industry

Todd Andrew Gross New World Productions, Inc.

1500 Jackson Street NE Suite 402, #181. Minneapolis, MN 55413 USA T: (612) 338-6448

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