DroneForce Studios LLC -·::· r:,-~:c:r-'T oc - .. l.r.l~l', 1 1'1·22 Kvlc: Hill Lanr: Stwar Land. Texas 77-17~) • Phone: W)')_')/8-<l/41 · .. ;:--J::;lr-,QI.'1·,tr··,l " t'J. -' - - " • _•• I ..,.•J) i/"'t \ 't• 

E-!vlail: aclmin(u:ldronelorcestudios.com \Veb: www.clronelorcestuclios.cot~1·· ·· -~:·;::- _..-,~,-l·;.::~· -- . ·--· ~--itJ\Jt.:\"J 

Date: 4·/IG/15 

United St;1tes Department of"T'ransponation 

Dockr:t ~'iauagemt~llt System 

1200 New.Jersey Ave., SE 

West Building Ground Floor Room WI2-J4.0 

Washington, DC 20:)90 

Rr:: Exr.rnption Request Pursuant To Section :):1:) or the FAA Refi:mn Act of 2012 

Dear Sir or Madam: 

.DOll 

We are writing pursuant to the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the 

procedures contained in 14- C.F.R. II, to request that DroneForce Studios LLC, an owner and operator of 

small unmanned aircral'l, be exempted from the Federal Aviation Regulations ("FARs") listed below so that 

Drone Force Studios, may operate its small unmanned aircraft I lightweight unmanned aircraft systems ("UAS") 

commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as 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. The conditions identified ami proposed by the applicant are drawn from Order 8900.1 CHG 0, 

Volume 3, Chapter 8-lssue a Certificate of Waiver for Motion Picture and Television Filming. As identified and 

described herein, Zainil Kacliwal, and his company DroneForce Studios, is an experienced, recognized veteran 

in the cinematography and photography industry. Mr. Kadiwal and his previous production experience have 

been producing and delivering great and unmatched quality videos .. !vlr. Kadiwal has also been an avid R/C 

model Oyer for over eight (8) years. Mr. Kadiwal has had extensive production service contracts with many 

entertainment multi-media conglomerates. DroneForce Studios has been actively involved in the technical 

development of UAS/UAV service applications to prm·ide high definition film quality by ae1ial cinematography 

\\~th small, unmanned aircraft and lightweight UAS. It is currently one of the very few companies that is 

developing advanced technical applications and abilities lor future commercial service applications. DroneForce 

Studios has fully equipped each of its small unmanned aircraft for aerial photography and cinematography, 

primarily lor use in the television broadcast industry, though given their stability and maneuverability, they may 

he used for other cinematography, by law enforcement personnel, search and rescue and by other first 

responders. 

To elate, DroneForce Studios has rejected all oilers to work with film, television, commercial tele\~sion 

production companies and directors on locations within the United States, to ensure it is in compliance with any 

applicable FARs. It, like other applicant~, has clone so clespite.Juclge Pauick G. Geraghty's decision in the 

Raphael Pirker matter and his reasoning that no FARs prohibit the use of small unmanned aircraft or 

•• 
lightweight UAS like those flown by other peer companies. DroneForce Studios exemption request would 

permit its operation of lightweigln, unmanned (remotely controlled in line of sight) UAS in tightly controlled 

and limited airspace. Predetermined, specifically marked areas of operation, cordoned ofrlocations and 

corresponding enhancements to current safety controls will allow DroneForce Studios to operate \\~thin current 

safety parameters and new ones being implemented. As identified, similar lightweight, remote controlled UAS 

are legally operated by amateurs \\~th 110 flight experience, safety plan or comrols itt place to prevellt 

catastrophe. DroneForce Studios is developing a state-of-theart client website applicatio11 to monitor, evaluate 

and implemellt all aerial cinematography acti\~ties with a pre-flight safety ami flight plan system. Graming 

DroneForce Studios request comports with the Secretary ofTransportation's (FAA Administrator's) 

responsibilities to not only integrate UAS into the national airspace system, but to" ... establish requirements for 

the safe operation of such aircraft systems [UAS] in the national airspace system" under Section 333(c) of the 

Reform Act. Further, DroneForce Studios \\~II conduct its operatio11s in complia11ce \\~th the protocols described 

herein or as otherwise established by the FAA. DroneForce Studios respectfully requests the grant of an 

exemption allowi11g it to operate lightweight, remote controlled UAS. The Specific Sections of Title 14 of the 

Code of Federal Regulations, Drone Force Studios. 

Equipment: (UAS) PJI Inspire I 

Requests Exemption are: 

14- CFR 21; 14- C.F.R. 4-5.23(b); 14- CFR 61.113 (a) & (b); 14- C.F.R. 91, et seq.; 14- CFR 4-07 (a)(l); 14- CFR 4-09 

(a)(2); and, 14- CFR 4-1 7 (a) & (b). 

Exemption Request Section 333 of the FAA Reform Act and Part II of the Federal A\~ation 

Regulations from 14- C.F.R. 4-5.230)); 14- CFR Part 21; 14- CFR G 1.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.1 03(h); 

91.1 09;91.1 19; 91.121; 91.151 (a);91.203(a) & (b);91.4-0S (a); 91. 407(a) (I); 91.409 (a) (2);91.41 7 (a) & (b). 

The Extent of Relief Drone Force Studios Seeks and the Reason It Seeks Such Relief": 

DroneForce Studios submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating to prevem DroneForce Studios contemplated 

commercial cinematic, research and other flight operations \\~thin the national airspace system. The Reform 

Act in Section 332 provides for such imegration of civil unmanned aircraft systems into our natio11al airspace 

system as it is in the public's interest to do so. DroneForce Studios lightweight UAS meet the definition of"small 

unmanned aircrafi'' as defined in Section 331 and therefore the integration of Drone Force Studios lightweight 

UAS are expressly contemplated by the Reform Act. DroneForce Studios would like to operate its lightweight 

UAS prior to the time period hy which the Reform Act requires the FAA to promulgate rules governing such 

craft. The Reform Act guides the Secretary in determining the tyves of UAS that may operate safely in our 

national airspace system. Considerations include: 
-------------------------------------------~ 

The weight, size, speed and overall capabilities of the Dji Inspire I; Whether the UAS will be operated near 

ai'lJOrts or populated areas; and, Whether the UAS will be operated by line ofsight.II2 P.L 95 § 333 (a). Each 

of these items militates in favor of an exemption for DroneForce Studios. Drone Force Studios UAS utilizes four 

counter-rotating propellers for extreme balance, control and stability. They each weigh less than 25 pounds, 

including cinematic or other equipment. Each ofDroneForce Studios small unmanned aircraft are designed to 

ptimarily hover in place and operate at less than a 35 knot maximum speed. They are capable of vertical and 

h01izomal operations but operate only within the line of sight of the remote comrol pilot. In addition to the 

remote comrol pilot, DroneForce Studios uses a spotter and a technician, such that, at minimum, three 

Drone Force Studios personnel govern the safe flight or an DroneForce Studios aircraft at all times. Utilizing 

banery power and not combustible fuels, flights generally last between five and twenty minutes DroneForce 

Studios does not operate ito; UAS with less than twenty five percent battery capacity. Safety systems in place 

include a G PS mode that allows DroneForce Studios UAS to hover in place if communication with the radio 

comrol pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. Further, 

DroneForce Studios Dji Inspire I is programmed, in some instances, to slowly follow a predetermined set of 

waypoints to return to a salety point if communications are lost. Drone Force Studios does not operate its UAS 

near ai'l)Orts and generally does not operate them near populated areas. The UAS operating software and G PS 

navigation systems do not allow any of the Drone Force Studios UAS vehicles to operate near aiq)orts or 

restricted Oy zones. The failsafe software will disable the UAS vehicles from taking orr and also limit the UAS 

systems from operating within specific G PS preset no-Oy zones. To date, Drone Force Studios has only operated 

its fleet on private sets, cordoned off areas ami areas under the control of DroneForce Studios clients. 

DroneForce Studios only operates its UAS in predetermined areas and only in compliance \\~th well regarded 

safety protocols such as those contained within the well established and commonly known Motion Picture and 

Tele\~sion Operations Manual. Drone Force Studios operation of its Dji Inspire I of small unmanned aircraft 

will not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 333 (b). Given the 

small size and weight ofDroneForce Studios UASs, combined with their operation in cordoned off ami wellcomrolled areas, DroneForce Studios Dji Inspire I falls within Congress's contemplated safety zone when it 

promulgated the Reform Act ami the corresponding directive to integrate UAS into the national airspace 

system. Indeed, DroneForce Studios UAS have a demonstrable safety record and do not pose any threat to the 

general public or national security. The FAA has the authority to issue the exemption to DroneForce Studios 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public 

Benefits Granting DroneForce Studios exemption request furthers the public interest. First, Congress has 

already pronounced that it is in the public's interest to imegrate commercially flown UAS imo the national 

airspace system, hence the passing of the Reform Act. Second, DroneForce Studios conduct~ research into safe 

UAS operations every time it flies one of its UAS. Flight data, \~sua! inspections, recorded observations and 

flight analyses are compiled to further enhance current safety protocols. Allowing Droneforce Studios to log 

more flight time directly relates to its research and its ability to further enhance current safety measures. Third, 

the public has an interest in reducing the danger and emission associated with current aerial cinematic capture 

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oo• 

methods, namely, full size helicopters. DroneForce Studios UAS are battery powered and create no emissions. If 

an DroneFon.:e Studios UAS crashes there is no li.1el to ignite and explode. The impact of Drone Force Studios 

lightweight UAS is far less than a lull size helicopter, notwithstanding the statistically noteworthy salety record 

ol"li.dl size helicopters used in motion picture capture. The public's interest is furthered by minimizing ecological 

and crash impacts by permitting motion picture capture through DroneForce Studios lightweight UAS. 

Progression of the arts ami sciences has been fundamental to our society since its inclusion in the United States 

Constitution. Indeed, Congress mandated the integration of UASs into our national airspace system, in part, to 

achieve progression in this noteworthy, and inevitable, lield. Permitting DroneForce Studios to immediately fly 

within the United States furthers these goals. \·Vhether it is the amalgam of scientilic discoveries applicable to 

leature lilm making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) 

to advancements in publicly usable technologies or advancements in equipment available to law enlorcement 

personnel I first responders that does not cost millions of dollars, granting DroneForce Studios exemption 

request substamially furthers the public's interest in ways known and currently unknown. 

Reasons Why DroneForce Studios Exemption Will Not Adversely Affect Safety Or How The Exemption Will 

Provide a Level of Safety At Least Equal To Existing Rule: DroneForce Studios exemption will not adversely 

affect safety. Quite the contrary, for the reasons stated, supra, permitting Drone Force Studios to log more flight 

time in FAA controlled airspace will allow DroneForce Studios to innovate and implement new and as of yet 

undiscovered safety protocols. In addition, DroneForce Studios submits the lollowing representations of 

enhancements to current aerial motion picture capture techniques: 

• DroneForce Studios UAS weigh less than 25 pounds complete 

• DroneForce Studios only operates its UAS below 300 feet; 

• DroneForce Studios UAS only operate lor 5-25 minutes per !light; 

• DroneForce Studios lands it'i UAS when they reach 25% battery power; 

• DroneForce Studios remote control pilots operate DroneForce Studios UAS 

by line of sight; 

• DroneForce Studios remote control pilots have video backup should they somehow 

lose sight ol"the UAS 

• DroneForce Studios stalE each flight with a remote control pilot, technician and 
• 

--------------------------------------<LMI 

spotter with communication systems enabling real time communication between them; 

Drone Force Studios UASs have G PS flight modes whereby they hover and then 

slowly land if communication with the remote colltrol pilot is lost or battery power is 

below25%; 

\ 

\ 

• DroneForce Studios actively analyses electronic flight data and other sources of 

information to constantly update and enhance safety protocols; 

• DroneForce Studios only operates in secured areas that are strictly colltrolled, are 

away from airports and populated areas; 

• DroneForce Studios conducts extensive briefings prior to flight, dming which safety 

carries p1imary importance; 

DroneForce Studios always obtains all necessary permissions and permits prior to operation; ami, 

Drone Force Studios has procedures in place to abort flights in the evem or safety breaches or potential 

danger. DroneForce Studios provides a level of safety at least equal to existing rules, and in nearly every 

instance, greater than existing rules. It is important to note that absent the integration of commercial 

UAS into our national airspace system, helicopters are the primary means of aerial motion picture 

capture. \,Vhile the safety record of such helicopters is remarkably astounding, it is far safer to operate a 

battery powered lightweight UAS. First, the potential loss of life is diminished because UAS carry no 

people on board ami DroneForce Studios only operates them in specific areas away from mass 

populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. Third, the small size and extreme maneuverability ofDroneForce Studios UAS 

allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when 

close enough to capture amazing images, DroneForce Studios UAS need not he so close to the objects 

they are focused 011. Accordingly, DroneForce Studios UAS have operated and will cominue to operate 

at and above currellt safety levels. 

A Summary The FAA i'day Publish in the Federal Register: 

A. 

14- C.F.R. 21 and 14- C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 
DOli 

14· C.F.R. 21, Subpart H, entitled Ainvorthiness Certificates, set~ forth requiremems for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(l). The size, weight and enclosed 

operational area or Drone Force Studios UAS permits exemption fi·om Part 21 because Drone Force 

Studios UAS meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the ainvorthiness certificate requirement under both the Act (49 

U.S.C. § 4-4-701 (Q) and Section 333 ofthe Reform Act. Both pieces oflegislation permit the FAA to 

exempt UAS from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability ami proximity ro areas such as ai'lJorts and dense populations. DroneForce Studios 

UAS meet or exceed each or the elements. 14· C. F.R. 91.7 (a) prohibits the operation or an aircrafi. 

without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (h) (2) requires an aircrart flight manual in the 

aircraft. As there are no pilots or passengers, ami given the size of the UASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maimaining a manual at the flight 

operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 

8737,8738,9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and32827. 

14· C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as DroneForce Studios UAS 

utilize electronic global positioning systems ami intemal gyroscopes to provide spatial coordination. I 4 

C.F.R. § 01.203 (a) and (h) provides for the carrying of civil aircraft certifications and registrations. They 

are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by 

maintaining such certifications and registrations at the DroneForce Studios flight operations center. 

B. 

I 4· C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

DroneForce Studios UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, two-inch letteting is diflicult to place 

on such small aircraft. Regardless, DroneForce Studios ,,~11 mark its UASs in the largest possible 

letteting on its fuselage as required by 14 C.F.R. §45.29 (Q so that the pilot, technician, spotter and 

others working \\~th the UA V \\~II see the markings. The FAA has pre\~ously issued exemptions to this 

n:gulation through Exemptions Nos. 8738, I 0167, I 0167 A and I 0700. 

~-l 
----------------------------------------~ 

oo• 

c. 

14 C. F. R. § 61.1 13: P1ivate Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (h), private pilots are limited to non-commercial operations. 

DroneForce Studios can achieve an equivalent level of safety as achieved by current Regulations because 

DroneForce Studios UAS do not carry any pilot~ or passengers. Further, while helpful, a pilot license \\~II 

not ensure remote control piloting skills, though DroneForce Studios pilot vetting and training programs 

will. Further, private pilot licensees will operate DroneForce Studios UAS \\~th the same skill. Further, 

the risks attendant to the operation of Drone Force Studios UAS is far less than the risk levels inherent in 

the commercial activities outlined in 14 C. F. R. § 61, et seq. Thus, allowing Drone Force Studios to 

operate its UASs with a private pilot as the pilot in control will exceed current safety levels in relation to 

14 C.F.R. §61.113 (a) &(h). 

D. 

14 C.F.R. 91.119: !vlinimum Safe Altitudes. 

14 C. F. R. § 91.1 19 prescribes sate altitudes for the operation of ci\~l aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. DroneForce Studios UAS will never operate at an 

altitude greater than 300 AGL. DroneForce Studios \\~II, however, operate its UASs in cordoned ofr 

areas with seCluity perimeters, providing a level of safety at least equivalent to those in relation to 

minimum safe altitudes. Given the size, weight, maneuverability ami speed of DroneForce Studios UAS, 

an equivalelll level of safety \\~II be achieved. 

I::. 

14· C. F. R. 91.4·05 (a); 4·07 (a) (I); 4·09 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to "have [the] 

aircraft inspected as prescribed in subpart E of this part and shall he tween required inspections, except 

as pro\~ded in paragraph (c) of this section, have discrepancies repaired as prescribed in part 4-3 of this 

chapter." These Regulations only apply to aircraft \~th an airworthiness certificate. They will not, 

therefore, apply to DroneForce Studios should its requested exemption be granted. Drone Force Studios 

conduct~ an extensive maintenance program that involves regular software updates and constant 

inspection for assessment of any damaged hardware. Therefore, an equivalent level of safety \\~II be 

achieved. DroneForce Studios has researched and developed its own designs. 

~) 

j 
Summary 

Drone Force Studios seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 

C.P.R. 45.23(h); 14 C.F.R. §§ Gl.II3 (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. § 91.15I(a); 14 C.F.R. 

§§ 91 .203(a) ami (b); 14· C.F.R. § 91. 4·0:""> (a); I+ C.F.R. § 91. 4·07 (a)( I); I+ C.P.R. § 91. '1-09 (a)(2); 14· 

C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.4·17 (a) & (l>) to commercially operate its fleet of small 

unmanned vehicles and lightweight unmanned aircraft vehicles in motion picture or television 

operations, to conduct its own research and to develop economic platforms for law enforcement I first 

responders, search and rescue. Granting DroneForce Studios request for exemption will reduce current 

risk levels ami thereby enhance safety. Curremly, motion picture image capture relies primarily 011 the 

use of larger aircraft running on combustible fuel. Drone Force Studios craft do not contain potentially 

explosive fuel, are smaller, lighter and more maneuverable than conventional motion picture aircraft. 

Further, DroneForce Studios operates at lower altitudes and in controlled airspace. DroneForce Studios 

has been analyzing flight data and other information in compiling novel safety protocols and the 

implementation of a flight operations manual that exceeds currently accepted means and methods of safe 

flight. There are no people on hoard DroneForce Studios UAS and therefore the likelihood of death or 

serious bodily injury is significamly limited DroneForce Studios operation of its UAS, weighting less than 

25 pounds and traveling at speeds lower than 35 knot~ in cordoned of1' areas will provide at least an 

equivalent level of safety as that achieved under current FARs. DroneForce Studios respectfully requests 

that the FAA grant its exemption request without delay. The FAA has the authority to issue the 

exemption sought by Drone Force Studios pursuant to the Federal Aviation Act, 85 P. L. 726 (1958), as 

amended (the "Act"). 

Sincerely, 

Zainil !vl Kadiwal, CEO 

DroneForce Studios, LLC. 

1422 Kyle Hill Lane 

Sugar Land, TX 774-79 
Corporations Section 

P.O.Box 13697 

Austin. Texas 78711-3697 

CERTIFICATE OF FILING 

OF 

DroneForce Studios LLC 

File Number: 802185419 

Carlos Cascos 

Secretary of State 

The undersigned, as Secretary of State of Texas, hereby certifies that a Certificate of Formation for the 

above named Domestic Limited Liability Company (LLC) has been received in this oftice and has been 

found to conform to the applicable provisions of law. 

ACCORDlNGL Y, the undersigned, as Secretary of State, and by virtue of the authority vested in the 

secretary by law, hereby issues this certitlcate evidencing filing effective on the date shown below. 

The issuance of this certitlcate does not authorize the use of a name in this state in violation of the rights 

of another under the federal Trademark Act of 1946, the Texas trademark law, the Assumed Business or 

Professional Name Act, or the common law. 

Dated: 03/30/20 15 

Effective: 03/30/2015 

Phone: (512) 463-5555 

Prepared by: Bridget Mouton 

Carlos Cascos 

Secretary of State 

Come visit us on the imerner ar hffp:/;)vww.sos.srare.rx.usl 

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I t:u!ifriM.:R 10 •· Sugar Land, TX 77 479 ____ ..:_ __ Jt!~!!.S!Y!!l.~~.Q!t:!.C!£.<!..VERAG_L ________ __ 'L ----·--- -~'=-~--- INSURED ! INSURER A · QB!; !D!I![i!l!l!!! Cl![l!l!r!!!Jon 100 39217 

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