Parallel Worlds Productions, LLC

Manager: Anthony Blaine

1111 S Orchard St

Suite 230

Boise, ID 83705

208­283­7983

U.S. Department of Transportation

Federal Aviation Administration

October 21st, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a)

and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR

91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1);

14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a)

and (b)

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform

Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Anthony Blaine, Manager, Parallel Worlds

Productions, LLC which owns and operates an Unmanned Aircraft System (UAS), hereby

applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow

commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors, would operate in the following manner:

­ Aerial photography and/or video for public and/or private use including real estate,

architecture, surveying, engineering and other related professional activities.

­ Aerial video and/or photography for public and/or private use including television, public

events, private events, cinematography and news gathering.

­ Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

­ Aerial inspection/photography or residential/commercial utility infrastructure including

but not limited to electrical power lines, wind turbines and cell towers.

­ Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

Parallel Worlds Productions, LLC operates One Hexo+ (6) blade Hexo­copter weighing 3.3

pounds. The UAS has a maximum airspeed of 45 miles per hour and uses a remote controller
operating on Bluetooth frequency range of 100m. The Hexo+ is equipped with built­in ground

support technology that allows it to fly utilizing global positioning system (GPS) for stability,

tracking, safe flight mode and a return­to­home feature in the event of loss of remote control

signal or critical low battery.

All flights start with a pre­flight safety check and all flight data are recorded. The Hexo+ is

equipped with a gimbal mounted camera that sends a live video signal to the controller allowing

the person in control (PIC) to monitor real­time video. Flight data, speed height, distance,

battery level and general aircraft conditions are also displayed during operation. The Hexo+

battery has a flight time of 10­15 minutes and is, therefore, always returned to original takeoff

point and always flown utilizing visual line of sight (VLOS). The Hexo+’s maximum range is

300ft vertical. Our request for exemption would allow us to offer unique aerial photography and

videography services to our clientele.

UAS Safety Operating Parameters

We will abide by the following additional operating conditions under this exemption, which

ensures a level of safety during UAS flight including operating the UAS below 400 feet and

within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from

the owner/controller of any vessels, vehicles and structures when operations may be conducted

closer than 500 feet to any such vessels, vehicles or structures. We will conduct a safety

assessment of the risk of operating closer to those objects and determine that it does not

present an undue hazard. Other safety operating

parameters include:

­ Operate the UAS for 15­20 minutes per flight.

­ Land UAS prior to the manufacturer's recommended minimum level of battery power.

­ Operate the UAS during daylight hours only within VLOS.

­ Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if

communication with the PIC is lost or battery becomes critically low.

­ Always obtain all necessary permissions prior to operation.

­ Have procedures in place to abort flights in the event of safety breaches or potential

danger.

­ Review weather reports prior to flight and never operate UAS in unsafe conditions, high

wind, low clouds or conditions that hinder visibility.

­ Only operate in safe environments that are strictly controlled, are away from power

lines, elevated lights, airports and densely populated areas.

­ Also conduct extensive preflight inspections and protocols during which safety carries

primary importance.

The PIC will also have a minimum of five hours logged on this craft and 10 hours minimum flying

UAS Hexo copters under varying conditions and environments and will follow all safety protocol

of Parallel Worlds Productions, LLC as well as guidelines of 14 CFR §61.51(b) having the ability
to safely operate the UAS in a manner consistent with the operating documents, including

evasive and emergency maneuvers and maintaining appropriate distances from people.

Specific Exemptions Requested

Given the size, weight, speed and limited operating area associated with the UAS, an

exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a)

and (b) (certifications required), subject to certain conditions and limitations, is warranted and

meets the requirements for an equivalent level of safety under 14 CFR Part 11 and Section 333

of P.L. 112­95 (Section 333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the

two­inch lettering is difficult to place on such a small aircraft with dimensions smaller than the

minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible

lettering by placing the word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so

that anyone will see the markings.

We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and

Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots or passengers nor

property. The Risks attendant to the operation of the UAS is far less than the risk levels inherent

in the commercial activities outlined in 14 CFR §61. The operation and limitations in the flight

operation manual (FOM) will equate to the safe operations of the UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operation of an aircraft

without an airworthiness certificate, since there is currently no certificate applicable to our

operation, this regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14

CFR 91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections

since they only apply to aircraft with an airworthiness certificate. However, as a safety

precaution, we will perform a preflight inspection of the UAS before each flight as outlined in the

attached operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft,

however, since there are no pilots or passengers on board the aircraft, and given its size, this

regulation is inapplicable. We believe an equivalent level of safety will be achieved by

maintaining a safety/flight manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight

and Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is

being used for flight instruction unless that aircraft has fully functioning dual controls. Although

the Hexo+ is capable of dual/linked controls, we will be operating with a single remote controller.

We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the

operation of civil aircraft, but allows helicopters to be operated at lower altitudes in certain

conditions. We will not operate our UAS above the altitude of 400 feet above ground level (AGL)
and will also only operate in safe areas away from the public and traffic, thus “providing a level

of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the

size, weight and maneuverability and speed of the UAS, an equivalent or higher level of safety

will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the

UAS utilizes electronic GPS with a barometric sensor. We request an exemption from 14 CFR

91.151(a) Fuel Requirements for Flight in visual flight rules (VFR) conditions. The UAS is 100

percent electric and two low battery alerts are issued – per the operating documents, the UAS

will be landed at the first alert. Also, our flights will last only 15­20 minutes each and the UAS

has an automated function, which results in immediate landing when a low battery is detected.

The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is

enough power to fly to the first point of intended landing and, assuming normal cruising speed,

land the UAS with 30 percent battery power remaining.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption

be provided:

1. Operations will be limited to the following aircraft described in the operating

documents which is a hex­rotor aircraft weighing less than seven pounds: Hexo+ Aircraft

System.

2. The UAS will not be flown at an indicated airspeed exceeding 45 mph.

3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by

the procedures specified in the operating documents.

4. The UAS will be operated within VLOS of the PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be operated within the

VLOS of the VO at all times. The VO and PIC will be able to communicate verbally at all

times. The PIC will be designated before the flight and will not transfer his or her

designation for the duration of the flight. The PIC will ensure that the VO can perform the

functions prescribed in the operating documents.

6. The operating documents will be accessible during the UAS operations and made

available to the Administrator upon request. Any revisions to the operating documents

will be presented to the Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

UAS will not be operated until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight. The Ground Control Station will be

included in the preflight inspection. All maintenance and alterations will be properly

documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight

characteristics, e.g. replacement of a flight critical component, will undergo a functional

test flight. The PIC who conducts the functional test flight will make an entry into the

aircraft records.
9. The pre­flight inspection section in the operating documents will account for all

discrepancies, i.e. inoperable components, items or equipment not already covered in

the relevant sections of the operating documents.

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection and life limit requirements.

11. We will carry out maintenance, inspections and record­keeping requirements, in

accordance with the operating documents. Maintenance, inspection and alterations will

be noted in the aircraft records, including total flight hours, description of work

accomplished and the signature of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer's Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an

aircraft in which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial videography/cinematography

and augmenting real estate listing videos (or similar operations), the PIC will have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of

five hours as an UAS pilot operating the make and model of the UAS to be used in

operations.

16. The PIC will not operate the UAS for the purpose of aerial

videography/cinematography and augmenting real estate listing videos (or similar

operations), unless the PIC has demonstrated and logged in a manner consistent with

14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the

operating documents, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

17. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1

All operations will be conducted under visual meteorological conditions (VMC).

18. The UAS will not operate within five nautical miles of an airport reference point as

denoted on a current FAA­published aeronautical chart.

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than three statute miles from the PIC.

20. If a UAS loses communications or loses its GPS signal, it will return to a

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

22. The PIC will not begin a flight unless, considering wind and forecast weather

conditions, there is enough power to fly at a normal cruising speed to the intended

landing point and land the UAS with 30 percent battery power remaining.

23. Before conducting operations, the radio frequency spectrum used for operation and

control of the UAS will comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.
24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available

to the PIC at the Ground Control Station of the UAS at any time the UAS is operating.

These documents will be made available to the Administrator or any law enforcement

official upon request.

25. The UAS will remain clear and yield the right of way to all manned aviation

operations and activities at all times.

26. The UAS will not be operated by the PIC from any moving device or vehicle.

27. The UAS will not be operated over congested or densely populated areas unless

contracted out to do events.

28. Flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UAS and/or debris in the event of an accident. We will ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UAS, flight

operations must cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission and the

PIC has made a safety assessment of the risk of operating closer to those objects and

determined that it does not present an undue hazard.

c. Operations near to the PIC, VO, operator trainees or essential persons do not present

an undue hazard to those persons per 14 CFR 91.119(a).

29. All operations will be conducted over private or controlled­access property with

permission from the landowner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

30. Any incident, accident or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable certificate of

authorization (COA) will be reported to the FAA’s UAS Integration Office (AFS­80) within

24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB)

per instructions contained on the NTSB website: www.ntsb.gov.

On behalf of Parallel Worlds Productions, LLC, I would like to thank you for your consideration

in

granting this exemption.

Signed,

Anthony Blaine

Parallel Worlds Productions, LLC
Here’s the exact specifications directly from Hexo+

Hexo+

Weight and dimensions

Length: 410 mm (without propellers)

Width: 435 mm (without propellers)

Height: 244 mm, 103 mm without feet

Weight: 1,5 kg (including battery and gimbal)

Power and Battery

Replaceable 5000 mAh 3S lithium­polymer battery

10 to 15 minutes of flight time per battery, depending on flight conditions

Propulsion

3 clockwise­ and 3 counterclockwise­rotating propellers

Custom design with maximum thrust/power ratio

Tool­free, screw­on assembly with color coded nuts matching the motors

6 Custom­designed motors

Color coded to match rotational motion with the right propeller

Maximum speed

45 mph (70 km/h)

Maximum range

Up to 300 ft (100 m) when using the Follow movement

Landing gear

Manually removable feet

Sensors

Digital compass

GPS antenna (compatible with GPS, GLONASS, Galileo, BeiDou, QZSS and SBAS)

Accelerometer

3­axis gyroscope

Gimbal

3­axis stabilisation (yaw, pitch, roll)

0° to 90° motion range on all 3 axis

Compatible with GoPro Hero3 and Hero4 Silver and Black

Removable without any tools

Bluetooth
V1.0, ~100 m range