Lane Wooder

T: +1 404 919 8430

lane@advancedaerialcine.com

November 24, 2014

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Par t 11 of the Federal Aviation Regulations from 14 C .F.R. 45.23 (b); 14 C.F.R. 21; 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 (b ); 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 . 91.407 (a) (1); 14 C.F.R. 91.409 ( a) (2); 14 C.F.R. 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the F AA Modernization and Reform Ac t of 2012 (the Reform Act) and 14 C.F.R. Part 11, A dvanced Aerial Cinematograp hy LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct a erial videography and photography for the motion pict ure, television, and commerc ial videography industry for closed set filming, hereby applies for an exemption from th e listed Feder al Aviation Regulations (“FARs”) to allow commercial operation of its sUASs , so long as such operations are conducted within a nd under the conditions outlin ed herein or as may be established by the FAA as required by Section 333.

As described more fully below , the requested exemption would p ermit the operation of small, unmanned and rel atively inexpensive sUAS un der controlled

conditions in the NAS that is 1 ) limited 2) predetermined 3) co ntrolled as to access. Approval of this exemption woul d thereby enhance safety and ful fill the Secretary of Transportation’s (the FAA Administ rator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is: Advanced Aerial Cinematography LLC

Attn: Lane Wooder

Ph: 404-919-8430 Email: lane@advancedaerialcine.com

Address: 5909 Chatham Court Tucker, GA 30084Regulations from which the exemption is requested:

14 C.F.R. 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 Co ngress’ goal in passing Section 333 (a) through (c) of the R eform Act. This law directs the Secretary of Transportation to consider wheth er certain unmanned aircraft sy stems may operate safely in the national airspace system (NAS) before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determinati on, the Secretary is required to determine which type s of UASs do not create a hazar d to users of the NAS or the public or pose a threat to nati onal security i n light of th e following:

• The UAS’s size, weight, s peed, and operational capability; • Operation of the UAS in close proximity to airports and popu lated areas; and • Operation of the UAS within vi sual line of sight of the oper ator.

Reform Act § 333 (a). Lastly, if t he Secretary determines that such vehicles “may operate safely in the national ai rspace system, the Secretary s hall establish requirements for the safe operation of such air craft in the national airspac e system.” Id . § 333 (c) (emphasis added).

The Federal Aviation Act expres sly grants the FAA the authorit y to issue exemptions. This statutory author ity by its terms includes exem pting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, f rom the requirement that

all civil aircraft must have a c urrent airworthiness certificat e.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any s ections 44702-44716 of this

title if the Administrator fi nds the exemption in the public in terest. 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).Advanced Aerial Cinematography' s sUASs are rotorcraft, weighti ng 50 or fewer lbs. including payload. They ope rate, under normal conditions a t a speed of no more than 40 knots and have the capabilit y to hover, and move in the vert ical and horizontal plane simultaneously. They will operate only in line of sight and wil l operate only within a predetermined and closed off property area under the permission of the property representative. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” as per the Reform Act Section 333 (b).

Given the small size of the sUAS s involved and the restricted sterile environment within which they will operate, t he applicant falls squarely wi thin that zone of safety (an equivalent level of safety) in w hich Congress envisioned that t he FAA must, by exemption, allow commercial opera tions of UASs to commence imme diately. Also due

to the size of the UASs and the r estricted areas in which the r elevant sUASs will operate, approval of the application pres ents no national security issue . Given the clear direction

in Section 333 of the Reform Act , the authority contained in th e Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit , including enhanced safety, redu ction in environmental impacts, including reduced emi ssions associated with allowing U ASs for movie and commercial videography operations, the grant of the requested e xemptions is in the public interest. Accordingly, the a pplicant respectfully reques ts that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein app ly to civil aircraft

that have the characteristics a nd that operate w ith the limitat ions listed herein. These limitations provide for at least an equivalent or even higher l evel of safety to operations under the current regulatory structure because the proposed ope rations are conducted on closed off property under the pe rmission of the property owner or property representative.

These limitations and conditions to which Advanced Aerial Cine matography agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh no more than 50 lbs. 2. Flights will be operated within l ine of sight of a pilot and /or observer. 3. Maximum total flight time fo r each operational flight will b e 20 minutes. Flights will be terminated at 30% battery pow er reserve should that occu r prior to the 20 minute

limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platfo rm from which filming is p lanned. If a structure being filmed or photographed has a he ight which exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the highest point on that s tructure. 5. Minimum crew for each operatio n will consist of the sUAS Pil ot, and the VisualObserver. 6. sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 40 hours of flight time with the s pecific sUAS equipment Advan ced Aerial Cinematography operates. The experience of the PIC will be certified by Advanced Aerial Cinematography through background checks and, if nec essary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Pri vate Pilots (Test Code: PAR or PRH). Advanced Aerial Cinematography will maintain f light logs of all PICs it employs, and provide full tran sparency to the FAA regarding the logs and records of

these PICs. 7. Flights will be operated at a la teral distance of at least 1 00 feet from any inhabited structures, buildings, vehicl es, vessels, or people not ass ociated with the operation or who have not signed a waiver i n advance of the operation. 8. A briefing will be conducted in regard to the planned sUAS o perations prior to each day’s production activities. It will be mandatory that all personnel involved with the operational duties of the fli ght within the boundaries of t he safety perimeter be present for this briefing. 9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the a ppropriate local Flight Stan dards District Office. 10. The operator will obtain the c onsent of all persons involve d in the filming and ensure that only consenting persons will be allowed within 100 fee t of the flight operation, and this radius may be re duced to 30 feet based upon an equ ivalent level of safety determination. With the advanced permission of the relevant FSDO, operations at closer range can be approved.

11. PIC and Visual Observer will have been trained in the opera tion of the specific sUAS equipment used by Advanced Aer ial Cinematography, and recei ved up-to-date information on the partic ular sUAS to be operated. 12. The PIC designated for any opera tion will have at least a C lass 2 medical certificate.

13. Visual Observer and PIC will at all times be able to commun icate by voice, radio,

and/or text. 14. Written and/or oral permission f rom the relevant property h olders or property representatives will be obtained. 15. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including l ocal law enforcement, fire, or other appropriate governmental agencies.

16. If the sUAS loses communica tion with the PIC or loses its G PS signal, the sUAS will have the capability to return to a pre-determined location within the Security Perimeter and land autonomously. 17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airw orthiness Certificates 14 C.F .R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthi ness certificates as required by F AR §91.203 (a) (1). Given the size and limited operating area associated with the aircraf t to be utilized by theApplicant, an exemption from Pa rt 21 Subpart H meets the requir ements of an equivalent level of safety under Part 11 a nd Section 333 of the Reform Act . The Federal Aviation Act (49 U.S.C.§44701 (f)) and Sec tion 333 of the Reform Act bot h authorize the FAA to exempt aircraft from the require ment for an airworthiness certi ficate, upon consideration of the size, weight, speed, ope rational capability, and proximi ty to airports and populated areas of the particular sUAS. I n all cases, an analysis of thes e criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safe r, than a conventional aircraft (fixed wing or rotorcr aft) operating with an airworthi ness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is 50 lbs. or less fully load ed, carries neither a pilot nor passenger, carries no explosiv e materials or flammable liqu id fuels, and operates exclusively within a secured ar ea. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety require ments, to provide security for the area of operation as is now done with conventional film ing. The FAA will have advance notice of all operations . These safety enhancements, wh ich already apply to civil aircraft operated in connection w ith motion picture and televis ion production, provide a greater degree of safety to the public and property owners than conventional operations

conducted with airworthiness cer tificates issued under 14 C.F.R . Part 21, Subpart H. Lastly, application of these same criteria demonstrates that th ere is no credible threat to national security posed by the s UAS due to its size, speed of o peration, location of operation, lack of explosive materi als or flammable liquid fuel s, and inabilit y to carry a
substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the re gistration number is displayed on limited, restricted or light-sport ca tegory aircra ft or experimental or provisionally certificated aircr aft, the operator must also dis play on that aircraft near each entrance to the cabin, cockpit, o r pilot station, in letters no t less than 2 inches nor more than 6 inches high, the words "li mited", "restricted", "light-s port", "experimental", or "provisional", as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be

needed as the sUAS will have no e ntrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sU AS, two-inch lettering will be impossible. The word “E xperimental” will be placed on t he fuselage in compliance with §45.29 (f).

The equivalent level of saf ety will be provided by having the s UAS marked on its fuselage as required by §45.29 (f) w here the pilot, observer, a nd others working with the sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued thefollowing exemptions to this regul ation as Exemption Numbers 10 700, 8738, 10167 and

10167A.

14 C.F.R. § 61.113 (a) & (b): Privat e Pilot Privileges and Limi tations: Pilot in

Command.

Sections 61.113 (a) & (b) limit pr ivate pilots to non-commercia l operations. Because the sUAS will not carry a pilot or pa ssengers, the p roposed operati ons can achieve the equivalent level of safety of c urrent operations by requiring t he PIC operating the aircraft

to have no less than 40 hours of fli ght time with the specific sUAS equipment Advanced Aerial Cinematography operates. The experience of the PIC will be certified by Advanced Aerial Cinematogr aphy through background checks and, i f necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). Advanced Aer ial Cinematography will maintain flight logs of all PICs it employs, and provide full transparency to the FAA regar ding the logs and records

of these PICs. The PIC desi gnated for any operation will have a t least a Class 2 medical

certificate. The risks associat ed with the operation of the sUA S are so diminished from

the level of risk associated wit h commercial operations contemp lated by Part 61 when drafted, that allowi ng operations of the s UAS by a PIC meeting the standards of Advanced Aerial Cinematography (listed above) exceeds the prese nt level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

Unlike a conventional aircraft t hat carries the pilot and passe ngers, the sUAS is remotely controlled with no living thi ng on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in adva nce. Currently there are no pilot licenses that are speci fic for UAS operators, and no curr ent FAA sanctioned pilot license of any type requires tr aining with, and knowledge of, U AS equipment greater than the requirements Advance d Aerial Cinematography uses to ce rtify its PICs. Therefore, the requirement of any available FAA sanctioned pilo t license to operate a sUAS does not make a PIC a more competent operator than one mee ting the requirements of Advanced Aerial Cinematography. Our company hopes the FAA de velops a new Pilot License specific for UAS and sUAS commercial operation, one tha t sets high standards on the quality of pilots and incre ases the professionalism of o ur emerging industry. If the FAA does this, Advanced Aerial Cinematography's PICs will be so me of the first to file for these licenses. Our compa ny would also be happy to work wit h the FAA to help develop the standards for new licenses, and any other regulatio ns the FAA is developing for UAS operation.

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.

The regulation requires that no pe rson may operate a civil airc raft unless it is in airworthy

condition. As there will be no air worthiness 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 for maintenance, and use of safety check lists prior to each flight (summaries listed below), an equivalent le vel of safety will be provided. Summarized Safety Checklists:1. Aircraft: All adjustment points will be checked for tightne ss; all motors and props will be inspected; all wiring will be double checked ; all systems will be powered up and checked for errors. 2. Battery: Confirmation will be m ade that batteries are fully charged and installed/connected properly. 3. Calibration: Pre-flight mot or/gyro calibration followed by confirmation of no errors with the flight and navigation systems. 4. Transmitter: Confirm radio transmitter has sufficient charg e, and is both working properly and receivi ng telemetry from the sUAS; co nfirm all switches are in pre-flight mode. 5. Surroundings/Flight Area: Conduc t one last visual inspectio n of the take-off surroundings and area of airspace sUAS will be operating i n. Confirm all people in the surrounding are as are associated with the fi lming being done.

6. Take-off Announcement: Before motors are started the PIC wi ll announce to a designated Representative (p erson of authority) of the fil m crew that sUAS is ready to take-off. Only after the Representative has notif ied all persons within the surrounding areas, and c onfirmed to PIC that they have clearance to lift-off,

will the motors be started and the sUAS will conduct its o peration. 7. Test Flight: A test flight will be conducted: after any dis assembly/reassembly; after replacement of any moto rs or flight el ectronics; aft er any pre-flight or in flight equipment errors that occur not resulting from envi ronmental conditions; very first thing of any comme rcial operations day before f ilming begins; if there are any concerns about environmental conditions and potential issues with the flight path.

14 C.F.R. § 91.9 (b) (2): Civil Air craft Flight Manual in the A ircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-re gistered civil aircraft ...

(2) For which an Airplane or Rot orcraft Flight Manual is not required by §21.5 of this chapter, unless there is a vailable in the aircraft a cur rent approved airplane or Rotorcraft Flight Manual, approved manual materia l, markings, and placards, or any combination thereof.

The sUAS, given its size and c onfiguration has no ability or pl ace to carry such a flight manual on the aircraft, not onl y because there is no pilot on b oard, but because there is no room or capacity to carry suc h an item on the aircraft.

The equivalent level of safety will be maintained by keeping th e flight manual at the ground control point where the PIC flying the sUAS will have im mediate access to it.

The FAA has issued the followi ng exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 328 27, and 10700.

14 C.F.R. § 91.103: Pre flight actionThis regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As F AA approved rotorcraft flight manuals will not be provided for the aircraft an e xemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landi ng and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. § 91.109: Flight instruction:

Section 91.109 provides that no pers on may operate a civil airc raft (except a manned free balloon) that is being used for f light instruction unless that aircraft has fully functioning

dual controls. sUASs and remotel y piloted aircraft, by their de sign do not have fully functional dual controls. Flight control is accomplished throug h the use of a control box

that communicates with the aircr aft via radio communications. T he FAA has approved exemptions for flight traini ng without fully functional dual co ntrols for a number of aircraft and for flight instruc tion in experimental aircraft. S ee Exemption Nos. 5778K & 9862A. The equivalent level of s afety is provided by the fact t hat neither a pilot nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civi l aircraft. Section 91.119 (d) allows helicopters to be operated a t less than the minimums pre scribed, provided the person operating the helicopter com plies with any route or alti tudes prescribed for helicopters by the FAA. As this e xemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 feet AGL, or not more than 200 feet above an elevated platform from which filming is plann ed, an exemption may be needed to allow such operations. A s set forth herein, the sUAS will never operate at higher than 400 feet AGL with the exception that in circumstanc es where the sUAS is used to survey or photograph a structure whose height exceeds 4 00 feet AGL, the UAS will not be operated more th an 100 feet above the highest point on the structure. It will however be operated in a restrict ed area with sec urity perimete r, where buildings and people will not be exposed to ope rations without their pre-obta ined consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS

as well as the location where i t is operated. No flight will be taken without the permission of the property owner or local o fficials. Because of the advanc e notice to the property owner and participants in the f ilming activity, all affected in dividuals will be aware of the planned flight operations. Compa red to flight operations with a ircraft or rotorcraft weighting far more than the maximum 50 lbs. proposed herein and the lack of flammable fuel, any risk associated with the se operations is far less tha n those presently presented with conventional aircraft opera ting at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the sUAS will ensure s eparation between these small UAS operations and the opera tions of conventional aircraf t that must comply with

Section 91.119.14 C.F.R. § 91.121 Altimeter Settings

This regulation requires each pe rson operating an aircraft to m aintain cruising altitude by

reference to an altimeter that is set “...to the elevation of t he departure airport or an appropriate altimeter setting ava ilable before departure.” As t he sUAS may not have a barometric altimeter, but inste ad a GPS altitude read out, an e xemption may be needed. An equivalent level of safety w ill be achieved by the operator, pursuant to the safety check list and live flight dat a monitoring, confirming the alti tude of the launch site shown

on the GPS altitude indi cator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirem ents for Flight in VFR Con ditions

Section 91.151 (a) prohibits an i ndividual from beginning “a fl ight in an airplane under VFR conditions unless (considering wind and forecast weather co nditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fl y after that for at least 30 m inutes; or (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the sUAS pr ovides no more than 30 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, s UAS flights would not be possible due to the reserve requi rement being equal to the maxi mum flight time. Given the limitations on the sUAS’s pr oposed flight area and the loca tion of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable.

Applicant believes that an e xemption from 14 C.F.R. § 91.151 (a ) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Mar tin Corporation to operate without compliance w ith FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only peopl e and property owners or offici al representatives who have signed waivers will be allo wed, with less than 30 minutes of reserve fuel, does not engender the type of risks tha t Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. Additionally, the limitations creat ed by this requirement for sUAS flights would essentially m ake null any utility for which the exemption will be granted.

Applicant believes that an equiva lent level of safety can be ac hieved by limiting flights to 20 minutes or 30% of battery power — whichever happens first. Th is restriction would be more than adequate to return the sUAS to its planned landing zo ne from anywhere in its limited operating area.

Similar exemptions have been gr anted to other operations, inclu ding Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) & (b): Carryi ng Civil Aircraft Certifica tion and Registration

The regulation provides in pertinent part:(a) Except as provided in § 91.715, no person may operate a ci vil aircraft unless it has within it the following:

(1) An appropriate and current a irworthiness certificate. . .

.

(b) No person may operate a civ il aircraft unless the airworth iness certificate required by paragraph (a) of this section or a special f light authorization issued under §91.715 is disp layed at the cabin or cockpi t entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no m ore than 50 lbs and is operate d without an onboard pilot. As such, there is no ability or place to carry certifica tion and registration documents or to display them on the sUAS.

An equivalent level of safety w ill be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immedia te access to them, to the extent they are applicable to the sUAS. The FAA has issued nume rous exemptions to this regulation. A representative samp le of other exceptions include s 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 “s hall have that aircraft inspected as prescribed in subpart E of this part and shall bet ween required inspections, except as provided in paragraph (c ) of this sec tion, have discr epancies repaired as prescribed in part 43 of this ch apter...,” and others shall ins pect or maintain the aircraft in compliance with Part 43.

Given that these sections and P art 43 apply only to aircraft wi th an airworthiness certificate, these sections will not apply to the applicant. Ma intenance and inspections

will be done in accordance with the sUAS Manufacturer's Manual, and will be performed by employees of Advanced Aerial Cinematography following the gu idelines and practices provided to us by the s UAS Manufacturer. An equivalen t level of safety will be

achieved because these small UAS s are very limited in size and will carry a small payload and operate only in restr icted areas for limited period s of time. If mechanical

issues arise the sUAS can la nd immediately and will be operatin g from no higher than

400 feet AGL. The PIC will ensure t hat the sUAS is in working o rder prior to initiating flight, perform required main tenance, and keep a log of any mai ntenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condi tion to provide the equivalen t level of safety.

Additional Views and Information

Advanced Aerial Cinematography h as realized the amazing benefit s sUAS equipment can provide to the film and televisi on industries. It not only prov ides new cinematographycapabilities, but als o increased safety ove r current and past p ractices that used larger and more dangerous equipment. Our c ompany wants to have the highest levels of safety and professionalism, and one thing ess ential to this is achieving a path to commercial licensing with the FAA. We believe this will help reduce unsafe practices, discourage improper uses, and improve public perception. The commercial ma nufacture and use of sUAS equipment will create more jobs for the United States and help boost the economies in many sectors, and we want to help the FAA in creat ing regulations that will allow incorporation of UAS devi ces into our country's airspace for commercial use.

********* Pursuant to 14 C.F.R. Part 11, th e following summary is provide d for publication in the Federal Register, should it be dete rmined that publication is n eeded:

Applicant seeks an exempti on 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; 91.12 1; 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 com mercially a small unmanned vehicle (50 lbs or less) in motion pictur e, television, and commercia l videography operations.

Approval of exemptions allowing c ommercial operations of sUASs in the film industry will enhance safety by reducing r isk. Conventional film operati ons, using jet or piston power aircraft, operate at extrem ely low altitudes just feet fr om the subject being filmed and in extreme proximity to peopl e and structures; and present the risks associated with vehicles that weigh in the ne ighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet he licopters.) Such aircraft mus t fly to and from the film location. In contrast, a sUAS w eighing fewer than 50 lbs. and p owered by batteries eliminates virtually all of tha t risk given the reduced mass an d lack of combustible fuel

carried on board. The sUAS is ca rried to the film set. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks assoc iated with manned aircraft flights.

The operation of small UASs, w eighting less than 50 lbs., condu cted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested here in, including exempting the app licant from the requirements of Part 21 and allowi ng commercial operations. The se lightweight aircraft operate at slow speeds, close to the ground, and in a sterile e nvironment and, as a result,

are far safer than conventiona l operations conducted with turbi ne helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access proper ty with the property representative or owner’s prio r consent and knowledge. Filming will be of people who

have also consented to being filmed or otherwise have agreed to be in the area wherefilming will take place. All flight s will occur in accordance w ith any state or local laws regarding privacy.

Satisfaction of the criteria provided in Section 333 of the Ref orm Act of 2012--size, weight, speed, operating capabilitie s, proximity to airports an d populated areas and operation within visual line of sight and national security – p rovide more than adequate justification for the grant of the requested exemptions allowin g commercial operation of applicant’s sUAS equipment in t he motion picture, television, a nd commercial videography industry.

Sincerely,

Lane Wooder Advanced Aerial Cinematography Owner and Operator