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

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act), and 

14 C.F.R. Part 11, Alpine Pro Media (APM), hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow commercial operation of APM’s sUAS/UAS in 

the NAS regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333, for the purposes of closed-set filming of motion pictures, music 

videos, web videos, corporate videos, television programs, commercials, still photography, 

wildlife/agriculture/conservation scientific data accumulation, product demonstrations and 

research and development.

Requested Exemption SummeryThe requested exemption would permit Alpine Pro Media to pursue commercial sUAS/UAS 

operations utilizing 2 advanced sUAS/UAS for the purposes of:

1. Aerial Photography/Cinematography and Videography in closed-set motion 

picture filming.

2. Wildlife/Agricultural/Conservation Surveying and Application.

3. Product Demonstrations.

4. Research and Development

Requested Exemption Aircrafts-
1. sUAS - DJI Inspire 1 - Previously granted in Exemption: 12422

2. UAS - VulcanUAV Raven X8 Airframe - Previously granted in Exemption 12008 and 11062 

(Xaircraft Super X Flight Controller - Previously granted in Exemption 11887 )

All APM’s sUAS/UAS are under 45lbs, and are incapable of flying over 25 knots, have a built-in 

GPS capability, hover and self-stabilization, navigation lights and failsafe/return to home (RTH) 

autopilot systems, which can be triggered manually by PIC(s), and automatically if 

communication between transmitter and receiver is interrupted. All operations occur with a PIC 

and a VO within VLOS over privately controlled closed-set property, and do so with the property 

owner/controller or authorized representative prior consent and knowledge, at no more then 400 

feet AGL. Persons who have consented or otherwise agreed to be in the area where purposed 

operations will take place may be captured in photos and/or videos.

Alpine Pro Media

Attn: Dan Sovince and Lucas Williford

AlpineProMedia.com

11568 SE Aquila ST

Happy Valley, OR

97086

FARs from which the exemption is requested Relief14 C.F.R. § 61.23(a) and (c)
14 C.F.R. § 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a)

14 C.F.R. § 61.315(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.409(a)(1) & (2)

14 C.F.R. § 91.417(a) & (b)

APM seeks relief extent from the above (FARs) to operate its sUAS/UAS’s commercially in the 

NAS for the purposes of closed-set filming of motion pictures, music videos, web videos, 

corporate videos, television programs, commercials, still photography, 

wildlife/agriculture/conservation scientific data accumulation, product demonstrations and 

research and development. 

Betterment of our Community.

APM believes that the use of sUAS/UAS to perform closed-set filming of motion pictures, music 

videos, web videos, corporate videos, television programs, commercials, still photography, 

wildlife/agriculture/conservation scientific data accumulation, product demonstrations and 

research and development, elevates the level of safety of such practices to the pubic and 

community in which they are conducted, do the nature of the sUAS/UAS industry and the 

standards in which they are conducted. The FAA already recognized, “UAS provides an 

additional tool for the filmmaking industry, adding a greater degree of flexibility, which 

supplements the current capabilities offered by manned aircraft.” See Exemption No, 11062
Equivalent Level of Safety.

APM’s sUAS/UAS(s) and operations meet and/or exceed standards listed below:

• APM will only operate its sUAS/UAS in VLOS of a PIC and a VO and operate at sites that are 

a “sufficient distance” from populated areas within the sterile private/controlled/closed-set 

property authorized for operations. Such operations will insure that APM will "not create a 

hazard to users of the NAS or the public."

• APM does not operate its sUAS/UAS(s) within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless specific operations 

deem necessary, a letter of agreement with that airport’s management will be obtained or 

otherwise permitted by a COA issued to APM.

• Maximum flight time for DJI Inspire 1 will be 20 minutes.

• Maximum flight time for VulcanUAV Raven X8 will be 60 minutes.

• Flights will be terminated at battery voltage of 3.72V per cell, the industry standard for lithium 

polymer batteries, which leaves 20% reserve, should that occur prior to the the maximum flight 

time.

• All operations will be operated at an altitude of no more than 400 feet AGL.

• APM’s PIC's will hold an airline transport, commercial, private, recreational, or sport pilot 

certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government.

• APM’s sUAS/UAS(s) weighs less than 55 pounds, including payload.
• APM’s sUAS/UAS(s) will operate at speeds of no more than 87 Knots.

• APM and/or PIC will ensure that the aircraft is in an “airworthy condition” prior to 

every flight, conducting pre-flight inspections and hands on inspections after every landing.

• APM will terminate operations if ANY damage and/or anomalies arise during 

flight or any part of its operations are compromised in anyway including unforeseen weather.

• APM will not operate DJI Inspire 1 when wind speeds exceed 20mph sustained. 

• APM will not operate VulcanUAV Raven X8 when wind speeds exceed 10mph 

sustained.

• APM’s sUAS/UAS(s) and the closed-set sterile environment within which they will 

operate, adhere to the Reform Act's safety requirements.

14 CFR 61.23 (a) and (c) Medical CertificatesRegulation provides that a person requires a first or second class medical to act as pilot in 

Command of an aircraft for compensation or hire. Our proposed operations require that the PIC 

must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. Since the aircraft cannot carry passengers or property, we feel we meet the intent 

of 61.23 even though the intent of this application is to conduct a business.

14 CFR 61.101(e)(4) and (5), 14 CFR 61.113 (a), and 14 CFR 61.315(a) Pilot privileges and 

LimitationsRegulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot 

certificate may act as PIC of an aircraft for compensation or hire. Our proposed operations 
require that the PIC must hold at least airline transport, commercial, private, recreational, or 

sport pilot certificate. Since the aircraft cannot carry passengers or property, we feel we meet 

the intent of 61.113 Subparagraph (b).

14 CFR 91.7(a) Civil Aircraft AirworthinessRegulation prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable.

14 CFR 91.119(c) Minimum safe altitudesRegulation states that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since operations of APM’s sUAS/UAS(s) 

would be photography or survey of persons, vessels, vehicles or structures it would be 

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over 

closed-set property or persons where permission has been obtained and careful preplanned/scripted flights are performed. The aircraft will be operated at low altitudes allowing, if a 

failure occurs, an emergency landing without undue hazard to persons or property on the 

surface. Therefore we maintain that due to the size(s) of APM’s sUAS/UAS(s), the hazard to 

persons, vehicles and structures/property is minimal compared to manned aircraft.

14 CFR 91.121 Altimeter settingsRegulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. APM’s sUAS/UAS(s) will always fly below 400 

feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other 

aircraft. An AGL altimeter measurement is transmitted via built in telemetry from the 

sUAS/UAS(s) (FC) Flight Controller through the sUAS/UAS(s) receiver and or ground station to 

the PIC’s on-screen display (OSD), providing a constantly updated AGL readout.

14 CFR 91.151(a)(1) Fuel requirements for flight in VFR conditions-
Regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at 

least 30 minutes. APM feels the intention of this paragraph is to provide an energy reserve as a 

safety buffer for flight delays. APM follow all industry standards attaining to lithium polymer 

battery charging/discharging and practices, and since operations will never be out of VLOS, 

commencing all flights at full charge will ensure that we meet the reserve energy requirement of 

this paragraph by terminating flights at or before 3.72v per cell.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, AlterationsRegulation provides that the operator is primarily responsible for maintaining the aircraft in an 

“airworthy condition”, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under 43.7" 

after maintenance and inspection. It is APM’s intention that APM and/or PIC’s perform strict 

maintenance and inspection’s that follow manufactures recommendations of the applied 

sUAS/UAS(s) parts and components and "be authorized to approve the aircraft for return to 

service."

APM and/or PIC’s will ensure that the aircraft is in an airworthy condition prior to every flight and

conducts hands on inspections after every landing to ensure an elevated level of safety of its 

operations. APM and/or PIC’s will document all maintenance, preventive maintenance and 

alterations performed in accordance with 91.417. APM feels that due to the size(s), 

construction, and simplicity of the aircraft, an equivalent level of safety is achieved.

SummeryAlpine Pro Media herein respectfully requests exemption from14 C.F.R. § 61.23(a) and (c)

14 C.F.R. § 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a)
14 C.F.R. § 61.315(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.409(a)(1) & (2)

14 C.F.R. § 91.417(a) & (b) 

Pertaining to the safe, commercial use of its sUAS/UAS in the NAS under closed-set controlled 

operations.

APM would like to add that it would be very easy to ignore the FAA and operate sUAS/UAS(s) 

commercially. We know of and have seen entities who are already doing so. We hope the 

simple fact that APM, who operate a very small media company, expresses our willingness to 

comply, and concern about sUAS/UAS operational safety, NAS and the community, by 

requesting this exemption.

Alpine Pro Media does not wish to exercise the above requested exemption outside the 

Continental United States.

Thank you for your time.

Sincerely

Alpine Pro Media

Attn: Dan Sovince & Lucas Williford

AlpineProMedia.com