May 20,2015 U.S

. Department of Transportation Docket Management System 1200 NewJersey Ave. SE Washington, DC 20590 FAA sUAS Exemption Request

Re: Exemption Request Section 333 of the FAA Reform Act
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Videolndiana, Inc., doing business as and publicly branded as WTHR TV, operator of Small Unmanned Aircraft Systems equipped to conduct aerial video recording and live photography for television, hereby applies for an exemption from the listed Federal Aviation Regulations {"FARs ") to allow commercial operation of its sUAS, 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 333.1. As described more fully below, the requ este d exemption would p e rmit th e operation of sma ll, unmann ed and re lative ly inexpensive sUAS under co ntrolled condition in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would provide saf ety e nh anceme nts to the a lre ady safe operations in the te levi s ion industry presently u s ing conve ntional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation' s (the FAA Administrator's) re spo n s ibiliti es to "

... establish requirem e nts for the saf ety operation of such aircraft systems in the national airspace system" Section 333 (c) of the Reform Act." The name and address of the applicant i s: Videolndiana, Inc. Larry Delia President & General Manager 1000 N

. Meridi a n St. Indianapolis , IN 46204 (317) 636- 1313 ld e lia@wthr. co m The conditions proposed by the app li ca nt a re drawn from order 8900.1CHG 0, Volume 3, ChapterS -Issue a Certification ofWaiverfor Motion Picture and Television Filming. This exemption application is expressly submi tted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Thi s l aw directs the Secretary of Tra n sportati o n to co n side r whether certain unmanned aircraft sys tems may operate safe ly in th e national a irspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform A ct. In making thisdetermination th e Secretary is re quired to determinew h ic h types of UASs do not c reate a hazard to users of the NAS or the public or pose a threat to national security in light ofthe following: -The UAS 's s ize, weight, speed and operational capability: -O peration ofthe UAS in close proximity to Airport, Powe r Plants , Fu e l D e pots and populated areas; and Op eration ofthe UAS within v isual line of sight of the operator. Reform Act * 333 (a) lastly , if the Secretary determines that such ve hicles "may operate saf ety in the national airspace system, the Secretary shall establish req uirements for th e safe operation of such aircraft in the national airspace system." I d.* 333 (c)(emphasis added) 2. The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. Thi s s

tatutory authority by its terms includes exempting civil aircraft, as the term is defined under *401 01 of the Act, which includes sUAS , from th e requirement that all civil aircraft must have a current airworthiness certificate. Applicant interprets thi s prov ision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of th e UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. The Administrator may grant an exemption from a requirement of a regulation prescribed under s u bsect io n (a) or (b) of thi s section or a ny section s 44702 -4471 6 of thi s tit le if the Administrator finds th e exe mpt ion in th e pub li c inte rest. 49 U .S.C. * 44701(f) See a l so 49 U SC *44704 ; 14 C FR *91.203{a) (1). Vi deolndi ana, Inc .'s s UAS are multi rotor craft , weighing 55 o r fewe r lbs. in clud in g payload. Th ey operate , under normal condi t io ns , at a speed of no more th a n 50 mph and have the capab ility to hove r and move in th e ve r ti ca l a nd ho ri zo nta l plane s imul taneo us ly. They will operate only in lin e of s ight a nd w ill operate only within th e ste ril e a rea describe d in the Videolndiana, In c . , Ge nera l Operation Manua l (hereinafter "GOM" ). Such o peratio ns will in s ure th at the s UAS wi ll "not create a haza rd to users of th e national a irspace system or the public." G ive n the s m a ll s i ze of th e s UAS in vo lved and the restri cted ste ril e envi ronme nt within w hi c h th ey will operate, th e app li ca nt falls sq u a re ly w ithin th at zo n e of safety (an eq uiva l e nt leve l of safety) in which Congress envisioned th at th e FAA must , by exempti o n , a ll ow co mm e rcia l operations of UAS s to co mmence immediately. Also due to th e s i ze of the UASs a nd th e restricted a reas in which th e releva nt sUAS will operate, approval of th e app li cation presents no nation a l sec urity issue. Given the clear direction in Section 333 of the Reform Act, th e auth o rity co ntained in the Fede ra l Aviation Act as ame nd ed, th e stro ng equivalent leve l of safety surrounding the propo se d ope rati o ns a nd the s i g nifi ca nt public benefit, including en han ced safety, reducti o n in e nv ironm enta l imp acts, in c lu d ing re du ced e mi ssio ns assoc i ate d with a llowing UASs f o r movie a nd t e lev i s i o n operat ion s, th e g ra n t of th e req u ested exe mpti o ns i s in th e public inte rest. Acco rdin g ly, th e applicant respectfully req u ests that t h e FAA gran t the re quested exe mpti o n without delay.
AIRCRAFT AND EQUIVALENT LEVELOFSAFETY T he appl i cant proposes that the exemption req u ested herein app ly to civil aircraft that have the cha racteri st ics and that ope rate with the l imitati ons li sted h ere in. Th ese li mi tat ion s provide for at le ast an eq uivalent o r eve n high e r level of safety to ope rati ons und e r the current reg ul atory stru cture because the proposed ope rat ions represen t a safety enhancement to the already safe movie and televi s ion f i l m in g operati o ns co ndu cte d with conven t iona l a ircraft.These limitations and conditions to which Videolndiana, Inc. agrees to be bound when conducting commercial operations under an FAA issued exemption include: The Videolndiana, Inc

. , GOM is a comprehensive outline of all flight operations and procedures. A reference copy will be kept with the sUAS operator at all times the sUAS is in operation

. An Aircraft Operating Manual covering the DJI Inspire I or any other aircraft which will be operated by Videolndiana , Inc. will also be kept with the sUAS operator at all times the sUAS is in operation. Reform Act Section 333(b) 

### 1. The sUAS will weigh less than 551bs. 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. 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 video recording is planned. 5. Minimum crew for each operation will consist of the sUAS pilot with a visual observer. 6. sUAS pilot will operate under the guidance and oversight of an FAA licensed airman with at least a private pilot certificate and a third class medical (if deemed necessary). 7. sUAS pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS pilot who possess the necessary PIC qualifications is also present on set (i.e. the Aerial Coordinator) that person can also be designated as PIC. 8. The UAS will only operate within a confined "Area of Operation" as defined in the GOM

. 9

. A briefing will be conducted in regards to planed sUAS operations prior to each day's production activities. It will be mandatory that all personnel that will be performing duties within the boundaries of the area of operations be present for this briefing. 10. The operator will file a FAA form 7711-1 or its equivalent as modified in light of the requested exemption with the appropriate Flight Sta ndards District Office (FSDO). 

### 11. The operator will obtain the consent of all persons involved in the video recording and e nsure that only consenting person s will be allowed within 

### 100 f eet of the flight operation and this radius may be reduced to 30 feet based upon an equivalent level of safety as described in th e GOM. With the advance permission of the relevant FSDO operations at closer range can be approved

. 

### 12. The operator will submit a written Plan of Activities to the FSDO three days before the propo sed shoot as required in the GOM. 13. All Videolndiana, Inc

. , crews will be trained in operations of UAS generally and will receive up -to -date information on the particular UAS to be operated as required in the GOM

. 14. Observer and Pilot w i ll at all times be able to communicate by voice

. 

### 15. Written and/or oral permission from the relevant property holders will be obtain e d. 

### 16. 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. 17

. lfthe sUAS loses communications or lo ses its GPS signal, the UAS will have capability to return to a predetermin e d location within the security perim eter and land. 

### 18. The sUAS will have the capability to abort a flight in case of unpredicte d ob stacle s or emergencies.14C.F.R. Part21, 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) (1). 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 ofthe 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 of the size, weight, speed, operational capability and proximity to airports, power plants, fuel depots and populated areas of the particular UAS. In the restricted environment and under the conditions proposed will be at least as safe as 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 551bs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels and operates exclusively within a secured area as set out in the General Operating Manual. Unlike other civil aircraft operations under this exemption will be tightly controlled and monitored by both the operator pursuant to the manual's requirements as well as under the requirements and in compliance with bcal public safety requirements, to provide security for the area of operation as is now done with conventional video recording. The FAA will have advance notice of all operations. These safety enhancements, which already applies to civil aircraft operated in connection with motion picture and televi s ion production, provide a greater degree of safety to the public and property owners than conventional operations conducted with a irworthiness 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 nat ion a l secu rity posed by the UAS, due to its size, speed and operation, location of operation, lack of explosive material s or flamm ab le liquid fuels and inability to carry a substantial external load. 14C

. F.R. *45.23 (b). Marking of theAircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited restrict ed or light-sport category aircraft or provisionally certificated aircraft, the operator must also display on that aircraft n ea r each entrance to the cabin, cockpit or pilot station in lette rs not les s than 2 inches nor more than 6 inch es high , the words "limit ed", "restricted", "light-sport", "experimental" or "provisional" as applicable. Even though the UAS will have no airworthiness certificate, a n exe mption may be needed as th e 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 s UAS , two inch l ette ring will be impossible

. The word "Experimental" will be placed on the fuselage in co mpliance with *45.29 (f).
The equivalent leve l of safety will be provided by having the s UAS marked on its fuselage as required by *45.29 (f) where th e pilot, observer and others working with the sUAS will see th e id en tifi cation of the UAS as "Experimental". Th e FAA has is s u ed the following exemptions to this Exemptions Nos.10700,8738 , 10167and 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 does 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 operate und e r the supervision of a private pilot's license holder rather than a commercial pilot's license holder

. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. Thearea of operation is controlled and restricted, the flights are planned and coordinated in advance as set forth in the GOM. The level of safety provided by the requirements included in the GOM exceeds thatprovided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. Th e risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted that allowing operations of the sUASas requested with a private pilot in a supervisory role aiding the PIC exceeds the present level of safety achieved by 14 C.F

. R. *61.113 (a) &(b). 14 C . F.R. *91.7(a): Civil aircraftairworthiness. The reg ulation 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 and the requirements contained in the General Operating Manual for maintenance as well as use ofsafety check lists priorto each fli ght, an eq uiva l ent l eve l 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 pe rso n may operate a U.S

.-registered civil aircraft

... (2) For which a n Airplane or Rotorcraft Flight M a nu a l i s not required by *21.5 of this chapter, unless there is available in the a irc raft a cu rre nt app rov ed airplane or rotorcraft flight manual, approved manual material, m a rking a nd placard or any combination thereof. Th e s UAS given its size and config uration has no ability or place to ca rry suc h a fli ght manual on the aircraft, not only because there i s no pilot on board but because there is no room or capac ity to carry such an item on the aircraft. The eq uiva lent level of safety will be maintained by keeping the flight manual at the ground cont rol point where the pilot fl y ing th e sUAS will have imm ediat e access to it. The FAA ha s issued the follo wing exemptions to this regulation : Exemption No s. 8607, 8 7 38, 9299, 9299A, 9565, 9565 8 , 10167 , 101 67A, 10602, 32827 and 10700

. 14C.F.R. * 91.103: Prefight action Thi s regu lation req uires each p ilot in command to take certain actions before flight to ins ure the safety of the flight. As FAA approved rotorcraft flight manual s will not be provided for th e aircraft an exemption will be needed. An equ iva lent l evel of safety will be prov i ded as set f orth in the Aircraft Operation Manual (AOM) fo r each UAS. The PIC w i l l ta ke all actions as described in th e GOM and AOM.14C.F.R. *91.109: Flight instructions: Section 

### 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is been used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fully functional controls. Flight control is accomplished through th e use of a control box that communicates with th e 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 passenger will be carried in the aircraft and by the size and speed ofthe aircraft. 14C.F.R. *91.119: Minimum safe altitudes Section 

### 91.119 establishes safe altitudes for operation for civil aircraft. Section 

### 91
. 119 (d) allows helicopters to be operated at less than the minimums prescribed, prov ided th e person operating the heli copter complies with any route or altitudes prescribed for helicopters by the FAA

. As this exemption is for sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 

### 400 feet Above Ground Level (AGL) or not more than 

### 200 feet above an elevated platform from which video recording is planned, an exemption may be needed to allow such operations. As set forth herein, except for th e limited conditions stated in the General Operating Manual, the UAS will never operate at higher than 

### 400 feet AG L. 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 notification and consent when required

. Th e equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it i s operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance noti ce to the property owner and participants in the video recording activity, all affected individu al s will be aware of the planned fight operation as set forth in th e GOM. Compared to fight operations with a ircraft or rotorc raft weighting far more than th e maximum 55 lbs

. proposed herein and the lack of flammable fu el, any risk associated with th ese operations i s far le ss than those presentl y presented with conventional aircraft operating at or below 

### 500 AGL in the movie industry. In addition, the low-a ltitud e ope ration s of the sUAS will ens ure sepa ra ti on between these sma ii-UAS operations a nd the operation s of convent i o na l aircraft that must comp ly with Section 

### 91.119.
14C.F.R. *91.121AitimeterSettings Thi s regulation requires each person operating an aircraft to maintain cruising altitud e by refe rence to an alti meter that is set "

... to th e e l evation of the departure airport or an app ropriate altimeter setting available before departure." As the s UAS m ay not have a barometric altimeter but in stead a GPS a ltitud e read out , an exempt ion may be needed. An eq uiva lent leve l of safety will be theoperator, pursuant to the General Operating Manual and Safety check li st, confirming the altit u de of the launch s ite s hown on the GPS altitu de indicator before f ight.14 C.F . R. *91.151(a): Fuel Requirements for Flight inVFR 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 th e day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Videolndiana, Inc. , requests relief from Section 91.151 due to the battery life that powers the sUAS. Typical aerial batteries provide approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR *91.151, sUAS flights would be limited to approximately 10 minutes in length. In relief of the 30-minute reserve , given the limitations on the UAS's proposed area of predetermined operation, a longer time frame for flight might be reasonable. As per Videolndiana, Inc .'s GOM, flight times will never exceed 75% of the battery(s) consumption or 25% reserve; whichever happens first. Applicants believes that an exemption from 14 CFR *9 1 .15 19(a) falls w ithin the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the sUAS in tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with l ess than 30 minutes of reserve fuel, does not engender the type of risk that Section 91.151 (a) was intended to alleviate given the size and speed of th e sma ll UAS

. Additionally, limiting sUAS flights to 10 minutes would greatly reduce th e utility for which the exemption wi ll be granted. Applicant believe th at an equivalent leve l of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happen s first. This restri ction would be more than adequat e t o return th e sUAS to its planned landing zone from anywhere in its limited operating area. S imil ar exemptions have b een g ranted to othe r operations, including Exemption 2689 F, 5745, 10673 and 10808

. 14C.F.R . *91.203 (a) 

### &(b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in * 91. 715, no p e rso n may ope rat e a civ il aircraft unl ess it has within it the fo llowing : (1) An appropr iate and cu rrent ai rworth iness certifi cate
... (a) N o person m ay operate a c iv il a irc raft unl ess the a irworth ine ss certifi cate req uired by pa ragrap h (a) of this section or a spec ial flight a uthori zation i ss ued und e r *9 1. 715 is disp layed at t he cab in o r cockpit entrance so th at it i s l eg ibl e to passengers or crew.The UAS fully loaded weighs no more than 55 lbs. and is operated without an on board pilot. As s uch , there i s n o ability o r pla ce to carry certification and registration do c uments o r to di sp lay th e m on th e sUAS

. Each s UAS operated by V ideolndi a na , Inc ., will be re g istered w ith the FAA and a ll documentation carried by th e PIC. A n equivalent l eve l of safe ty will be achieved by keeping these documents at the ground co ntrol point where th e pilot fly i ng th e sUAS wi ll have immediate access to them , to th e extent they are applicable to the sUAS. The FAA has i ss ued numerous exemptions to this regul ation. A repre se ntati ve sample of other exceptions includes Exemption N os. 9565, 9665, 9789, 9789A, 9816A and 10700

. 14C . F. R. *91.405(a); 404(a) (1);409(a) (2); 417(a) 

### &(b) : Maintenance Inspections These regulations require that an a ircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prov id ed in paragraph(c) of this section , have di sc repancies rep a ired as prescribed in part 43 of this chapter

... " and others sha ll inspect o r maintain the aircraft in compliance w ith Part 43. Gi ven that these sections and Part 43 appl y onl y to aircraft with airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the guidelines set forth in the maintenan ce manu a ls designed for each UAS. An equivalent level of safety wi ll be achieved because th ese sma ll U ASs are very limited in size and will ca rry a sma ll payload as we ll as operate only in re stricte d a reas for limited pe ri ods of tim e. If mechanical iss ues arise the UAS can la nd immediately and will be operating from no high e r th a n 400 feet AGL. As provided in the GOM, the operator will ens ure that th e UAS i s in working order pri o r to initi at ing flight , perform required m a inten an ce a nd ke ep a lo g of any m a intenance performed. Moreover, the operator i s th e person most fa m i li ar with the a ircraft and best s uited to m a intain the a ircraft in an airwo rth y condition to provide th e eq ui va lent level of safety.

Purs u ant to 14 C.F. R Pa rt 11 , th e fo llowing s ummary is provided for publication inthe Federal Reg i st e r , s h o uld it be determined th at publication is need ed: Videolndiana , In c. seeks an exe mpt ion from the follo w in g rule s: 14 C.F.R. *21 s ub part H; 14 C.F.R. 45 .23(b); 14 C

. F .R. *6 1

. 113(a ) & (b); 91 .7( a); 91.9(b) (2); 9 1.103(b) ; 91.109; 91.119; 9 1 .12 1 ; 9 1

. 1 51 (a); 9 1.20 3(a) & (b); 9 1.40 5(a); 91.407(a) ( 1) ; 9 1.409 (a) (2); a nd 9 1.417(a) 

### & (b) to operate commercia ll y a small unm a nn ed veh i cle (55 lb s. or less) in video reco rdin g and television operations. Approval of exemptions a llowin g co mm erc ia l ope ration s of s U AS in th e vid eo reco rdin g and crea ti on indu stry w ill enhance safety by red ucing risk. Conventional video recording operations us in g j et or p i ston powe r a irc raft, operate at extreme ly l ow a ltitud es just feet from th e s ubj ect be in g re corded and in extreme p roxim ity to people and stru ctures a nd present th e ri s ks assoc iat e d w ith ve hi c l es th at we i gh a pproximately 4000 lb s . a nd ca rry l a rge amo unts ofj et A or other fuel (1 40 ga llon s forj ethelicopters ,e.g.). Suc h ai rc raft mu st f ly to a n d from the re cord locat ion

. In co ntrast , a sUAS we i g hin g fewe r th a n 551b s and powe red by batteries el imin ates vi rtu a ll y a ll of that ri s k give n th e re du ced mass a nd l ack of comb u stibl e fu el ca rri e d on board. Th e s UAS i s ca rri ed to th e record locat ion a nd not flow n . The s U AS w ill ca rry n o passe ng e rs or c rew and th erefo re w ill not expose th e m to th e risks assoc i ated w ith m a nn e d aircraft flights. Th e operation of sma ll UASs weigh in g l ess than 55 lb s., condu cted in th e stri ct co nditions out lin ed above w ill provid e an e quiva l e nt leve l of safety supporting th e g rant of the exempti o n requ est h e rein , includin g exempt in g th e app li cant from the requirements of Part 2 1 and a ll owi ng co mm e rc i a l operations. The se li g htwe i ght a irc raft operate at slow speeds, c l ose to th e ground and in a st e rile environment and as a re s ult a re far saf e r than conve ntion al ope rati ons co nducted with turbine h e li copt e rs operating in cl ose proximity to th e ground and peop l e.

Privacy A ll f lights will occur ove r pri vat e o r co ntrolled access property with th e prop erty owner's prior consent a nd knowledge. Video reco rding w ill be of people who have also conse nted t o being v id eo recorded o r otherwise h ave agreed to be in the area w h e re th e vid eo reco rdin g will take pl ace. Satisfaction of the c riter i a prov i ded in Sect ion 333 of the Reform Act of 2 012 - size, weight, s peed

. ope rat in g capab iliti es , prox imity to a irports a nd pop ul at ed a reas, as well as operat i on within v i s u al li ne of sight a nd nat i o n a l sec urity -prov id e mor e th a n adequ ate ju s tificati on for the g ra nt of the reque st ed exemptions a ll owing co mmercial opera ti o n of ap plica nt' s UAS in the moti o n pictu re and tele v isio n indu stry pursuant to th e M anua l a ppe nd ed he reto. Accordingly , V id eo l ndi ana , In c. respectfu ll y requests that t he FAA g ra nt its exemptio n requ est set fo rth he rei n . Respectfull y.

In dianapol i s , IN 46 2 04 (317)636-1313