Thomas Legal Solutions 

9048 Halkirk Way, Sacramento, California 95829 

Email: info@thomaslegal.net • Phone: (650) 793 - 7129 

1 

October 28, 2015 

U. S. Department of Transportation 

Docket Management Facility 

1200 New Jersey Avenue SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Re: Request for exemption (pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regs) from: 14 CFR Part 21; 14 CFR 45.23(b); 14 CFR 

61.113(a)&(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103(b); 14 CFR 91.109; 

14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)&(b); 14 CFR 

91.205(b)(3)&(4); 14 CFR 91.215; 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 

91.409(a)(1)&(2); 14 CFR 91.417(a)&(b). 

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, Spirit of Space, LLC ("Applicant"), established architectural 

filmmaker1 and proposed/intended operator of certain small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography for purposes of filmmaking, 

cinematography and videography, hereby applies for exemption from the listed Federal 

Aviation Regulations (“FARs”), and any additional regulations that the FAA may deem to 

apply or be relevant to the subject matter hereof, to allow commercial operation of its 

sUAS(s) within and under the conditions outlined herein, or as may be established by 

the FAA pursuant to Section 333. The particular sUAS(s) for which exemption is sought 

is/are listed in Exhibit A. We originally intended to attach, as additional Exhibits, the 

official User Manual (together with relevant associated materials, e.g. Safety Guidelines, 

Maintenance Manual, etc.) for each sUAS for which we request exemption. However, 

we have recently learned that the FAA does not (or does not any longer) require 

submission of such materials in support of Section 333 exemption requests.2

 We have 

therefore omitted them, but would be happy to provide them upon request. 

 

1

 Spirit of Space, LLC has been in continuous operation in the field of architectural photography, 

filmmaking, cinematography and videography since 2006. It has also won a number of major awards 

during that time. 

2

 See FAA document titled "Section 333 Petition Guidance & Checklist," sixth square bullet point, located 

at: http://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/Section333-Petition-Checklist.pdf. 
2 

As described more fully below, the requested exemption would permit the operation of 

certain small, unmanned sUAS(s) under controlled conditions in airspace which is both 

limited and predetermined and under circumstances which would provide substantial 

safety enhancements as compared with the operations presently conducted in the 

filmmaking, cinematography and videography industry using conventional manned 

aircraft. Approval of this exemption would thereby enhance safety, and so be 

manifestly in the public interest, and would fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) mandate and authorization under Section 333(c) of the Reform Act 

to “...establish requirements for the safe operation of such aircraft [i.e. UAS] systems in 

the national airspace system.” 

The name and address of Applicant is: 

Spirit of Space, LLC 

53 W. Jackson Blvd, Suite 1456 

Chicago, IL 60604 

•→ However, please direct all correspondence and other communications 

regarding this petition, for and on behalf of Applicant, to: 

Terry L. Thomas 

Thomas Legal Solutions 

9048 Halkirk Way 

Sacramento, CA 95829 

E: terry@thomaslegal.net 

C: (650) 793 - 7129 

A. OVERVIEW 

Regulations from which exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113(a)&(b) 

14 C.F.R. 91.7(a) 

14 CFR 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 CFR 91.151(a) 

14 CFR 91.203(a)&(b) 

14 CFR 91.205(b)(3)&(4)

14 CFR 91.215 

14 CFR 91.405(a) 

14 CFR 407(a)(1) 

14 CFR 409(a)(2) 

14 CFR 417(a)&(b) 

This request for exemption is expressly submitted to fulfill Congress’ goal in passing 

Sections 333(a) through (c) of the Reform Act. The aforementioned law directs the 
3 

Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before completion of rulemaking as 

required pursuant to Section 332 of the Reform Act. In making this determination, the 

Secretary is directed to determine which types of UASs do not create a hazard to users 

of the NAS or to the general public, nor pose a threat to national security, in light of the 

following (Reform Act §333(a)): 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, which includes sUASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate. The Administrator may grant 

an exemption from a requirement of a regulation prescribed under subsection (a) or (b) 

of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption to be in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 

49 USC §44704; and 14 CFR §91.203(a)(1). 

Applicant's sUASs are rotorcraft, weigh well under 55 lbs (typically even less than 10 

lbs), inclusive of payload, and are battery powered (hence carry no fuel). They typically 

operate at well below the (87 knot/100 statute mph) maximum speed previously 

established by the FAA in grants of exemption similar to the one requested in this letter. 

They are the functional equivalent of helicopters (the term used in many of the relevant 

regulations), having the ability to hover, and to move in the vertical and horizontal plane 

simultaneously. They will be operated only in visual line of sight and within limited and 

predetermined areas and environments associated with each video project "shoot" 

location. Such operations will ensure that the sUASs do "not create a hazard to users of 

the national airspace system or the public.” Reform Act Section 333(b). 

Given the limited size, weight and speed of the sUASs at issue, and the limited and 

predetermined areas and environments within which they will operate: (i) Applicant 

would seem to fall squarely within that zone of safety (i.e., an equivalent level of safety) 

within which Congress envisioned and directed that the FAA, by exemption, allow 

commercial operations of UASs; and (ii) operation of the sUASs presents no issues 

involving national security. Given the clear mandate and authority given the FAA in 

Section 333 of the Reform Act, the general authority contained in the Federal Aviation 

Act, as amended, the strong equivalent level of safety surrounding Applicant's proposed 

sUAS operations, and the significant public benefit involved, including but not 

necessarily limited to enhanced safety (given, e.g., their much smaller size and lower 

airspeed, absence of flammable fuel tankage, etc.), reduction in environmental impact 

(e.g. absence of fossil fuel exhaust emissions, significantly reduced noise "pollution," 

etc.), we believe that grant of the requested exemption is clearly in the public interest. 
4 

Accordingly, Applicant respectfully requests that the FAA grant the requested 

exemption without undue delay. 

B. AIRCRAFT OPERATIONS; EQUIVALENT LEVEL OF SAFETY 

Applicant proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations/conditions listed in this Section 

below. We believe these limitations/conditions provide for at least an equivalent level 

of safety as compared to operations under the current regulatory structure. The 

limitations/conditions which Applicant proposes to follow when conducting commercial 

operations include:3

1. The sUAS will weigh less than 55 lbs fully loaded at the time of takeoff. 

2. Flights will be operated at an altitude of no more than 400 feet AGL. 

3. Flights will be operated at speeds not exceeding 87 knots (100 statute 

mph). 

4. Minimum crew for each operation will consist of the sUAS Pilot-inCommand ("PIC"), and a Visual Observer ("VO") capable of two-way 

verbal communication with the PIC. 

5. Flights will be operated within visual line of sight of the PIC and/or VO 

at all times. 

6. The sUAS PIC will be an FAA licensed airman holding (at a minimum) a 

current, valid sport pilot’s certificate and a current, valid driver's license 

issued by one of the 50 United States or the District of Columbia. 

7. If the sUAS loses communications or loses its GPS signal, the UAS will 

have capability to return to the launch point (or to another nearby predetermined location) within the area of sUAS operations. 

8. Flights will be terminated by the PIC, at the latest, whenever the 

sUAS's battery has been discharged to twenty-five percent (25%) of 

capacity.

 

3

 This list is informed by and proposed in conformance with various exemptions recently granted by the 

FAA under circumstances substantially similar to those described in this letter, as applying to Applicant 

and to commercial operations of the sUAS system(s) for which exemption is requested. The FAA is 

obviously free to impose alternate or additional requirements pursuant to its rulemaking and exemptiongrant authority, and inclusion of this list is in no way intended to suggest otherwise. 
5 

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

14 C.F.R. Part 21, 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 Applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

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 and populated areas of the particular UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The sUAS(s) to be operated hereunder are less than 55 lbs fully loaded, carry neither a 

pilot nor passenger(s), carry no flammable liquid fuels or other combustible materials, 

and will be maintained and operated in accordance with each sUAS's respective official 

User Manual (together with any relevant associated materials, e.g. Safety Guidelines, 

Maintenance Manual, etc.), except as may further be limited by the list of restrictions 

proposed above, and/or other conditions/restrictions as the FAA may establish in its 

grant of exemption. Furthermore, there is no credible threat to national security posed 

by operation of the UAS(s) as set forth herein, due to their limited size and speed, 

limited size of each video "shoot" locale (typically a single large structure or complex, 

together with its immediate environs), duration and scope of operation, lack of 

flammable liquid fuels or other combustible materials, and inability to carry any 

substantial payload. 

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

The cited regulation requires: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though (assuming FAA grant of the preceding requested exemption) the UAS will 

have no airworthiness certificate, an exemption may be needed as the UAS will have no 
6 

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Also, given the size of the sUAV, the requirement for (at a minimum) two-inch 

lettering will be impossible to satisfy. The FAA has previously issued (at least) the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A, 11062, 11109, 11112 and 11213. We respectfully request a comparable 

exemption from this requirement. 

E. 14 C.F.R. § 61.113(a)&(b): Private Pilot Privileges/Limitations: Pilot in Command.

Sections 61.113(a)&(b) limit private pilots to non-commercial operations. Because the 

UAS will not carry either pilot or passenger(s), and given its much smaller size and 

weight as compared with even the smallest manned aircraft, the proposed operations 

can achieve the equivalent level of safety of current manned operations by requiring the 

PIC operating the UAS to have an FAA sport pilot’s license (or better) and current valid 

US driver's license, as established in previous grants of exemption made in 

circumstances substantially similar to those described in the instant exemption request. 

It is our considered opinion that the risks associated with operation of the sUAS(s) as 

proposed in this letter are so diminished in comparison with the general level of risk 

associated with commercial operations contemplated by Part 61 at the time of its 

drafting, that allowing operations as requested herein will substantially exceed the 

present level of safety achieved by 14 C.F.R. §61.113(a)&(b). 

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9(b)(2) provides in pertinent part: 

No person may operate a U.S.-registered civil aircraft ... [f]or which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. (emphasis added)

The sUAS, given its size and configuration, has no room or capacity to carry such a flight 

manual on the aircraft itself, nor would inclusion of such a manual seem to serve a 

purpose cognizable by the relevant statutory/regulatory structure, given that there will 

be no pilot on board the sUAS. However, we are of the opinion that an equivalent level 

of safety, serving the relevant statutory/regulatory purpose, will be maintained by 

keeping the official User Manual (together with any relevant associated materials, e.g. 

Safety Guidelines, Maintenance Manual, etc.) at the sUAS ground control point, where 

the PIC will have immediate access to it at all times relevant to operations. The FAA has 

issued (at least) the following exemptions to this regulation under similar circumstances: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

10700, 11062, 11109, 11112 and 11213. We respectfully request a comparable 

exemption from this requirement. 
7 

G. 14 C.F.R. § 91.103: Preflight action 

The cited regulation requires each pilot in command to take certain actions before flight 

to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. An equivalent level of safety will 

be provided by conforming Applicant's sUAS maintenance and operations to its 

respective official User Manual (together with any relevant associated materials, e.g. 

Safety Guidelines, Maintenance Manual, etc.), and to those conditions and limitations 

set forth in the relevant FAA-issued exemption. 

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

Section 91.103 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. We observe that sUASs and other remotely piloted aircraft, 

by design, are not (except, perhaps, in rare and specialized circumstances) fitted with 

dual flight controls. Rather, flight control is accomplished through the use of a control 

box that communicates with the aircraft via radio communications. The FAA has 

previously approved exemptions for flight training without fully functional dual controls 

for a number of aircraft and for flight instruction in certain experimental aircraft. See, 

e.g., Exemptions Nos. 5778K & 9862A. In the case of Applicant's sUAS(s), we believe that 

an equivalent level of safety will be established by the fact that neither a pilot nor 

passengers will be carried in the aircraft, by the size and speed of the aircraft, by other 

aspects of the sUAS(s) at issue (for example, battery power as opposed to flammable 

fuel tankage) and by other limitations and restrictions on operations as proposed 

herein, and as the FAA may otherwise establish in its grant of exemption. We therefore 

respectfully request exemption from this requirement. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is functionally equivalent to 

a helicopter and the exemption requests authority to operate at altitudes below 400 

feet AGL, an exemption may be needed to allow such operations. 

J. 14 C.F.R. §91.121 Altimeter Settings 

The cited regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the sUAS may 

not have a barometric altimeter, but instead a GPS altitude read out, an exemption may 
8 

be needed. The GPS system implemented in Applicant's current sUAS allows the PIC to 

set a maximum flight ceiling which the sUAS is programmed then automatically not to 

exceed. In any case where automatic implementation of flight ceiling restrictions is (for 

whatever reason) not possible, we believe and respectfully submit that an equivalent 

level of safety will be achieved by the PIC confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight, and thereafter ensuring that the sUAS 

does not exceed this baseline altitude + 400 feet. 

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 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 the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 

The batteries powering current leading professional-level UAS models may -- depending 

on make and model -- be rated to provide less than, or only slightly more than, 30 

minutes of flight time in toto on a full charge (for example, the DJI Inspire 1 model listed 

on Exhibit A is rated to provide somewhat less than 30 minutes of flight time in toto on a 

full charge). Therefore, it may be difficult or impossible to meet the 30 minute reserve 

requirement in 14 CFR §91.151(a), and even in cases where meeting such a requirement 

is technically possible, it presents certain obvious practical difficulties, as even in such 

cases sUAS flights would of necessity be limited to only a few minutes in length, greatly 

reducing the utility for which the instant exemption is requested. 

Given the limitations on the sUAS’s proposed flight operations, the localization of each 

on-site video "shoot" to within a relatively small, fixed, limited and predetermined area, 

the sUAS's small size and weight, its lack of flammable fuel or other potentially 

dangerous payload, its constant proximity to and VLOS observation by the PIC and VO, 

the ease and rapidity with which it can complete safe landing and recovery (both in 

absolute terms, and as compared with conventional manned aircraft, particularly fixedwing aircraft which require established runways and other ground support facilities for 

safe landing), etc., we respectfully submit that a longer time frame for flight would 

appear reasonable in the instant case, and believe that such an exemption from 14 CFR 

§91.151(a) would in our case fall within the scope of prior granted exemptions. See, e.g., 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151(a)). For all the reasons given in this paragraph above, we 

respectfully submit that grant of such an exemption does not engender the types of 

risks that Section 91.151(a) was intended to alleviate. 

Applicant believes and respectfully proposes that an equivalent level of safety can be 

achieved by limiting flights to a duration which will be terminated by the operator 

whenever only twenty-five percent (25%) of battery power is remaining. This restriction 
9 

would be more than sufficient to safely return the sUAS to its planned landing zone 

from anywhere in its limited operating area. We note that the FAA has issued (at least) 

the following exemptions to this regulation under similar circumstances: Exemption 

Nos. 2689F, 5745, 10673, and 10808. We therefore respectfully request an exemption 

from this requirement. 

L. 14 C.F.R. §91.203(a)& (b): Carrying Civil Aircraft Certification and Registration 

The cited regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it ... [a]n appropriate and current airworthiness 

certificate[.] 

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the sUAS. However, an equivalent level of safety will 

be achieved by keeping these documents at the sUAS ground control point, where the 

PIC will have immediate access to them to the extent they are applicable to the sUAS or 

its operations. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 

9789A, 9797, 9797A, 9816A, and 10700. 

M. 14 C.F.R. §91.405(a); 407(a)(1); 409(a)(2); 417(a)&(b): Maintenance Inspections 

The cited regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and that others shall inspect or maintain the 

aircraft in compliance with said Part 43. 

Given that these regulations and Part 43 apply only to aircraft with an airworthiness 

certificate, and assuming the FAA grants the exemption requested in Section C of this 

letter above, they would seem by their terms not to apply to Applicant. We respectfully 

submit that an equivalent level of safety will be achieved in the following way: (i) sUAS 

maintenance will be accomplished by Applicant pursuant to manufacturer 

recommendations as set forth in its respective official User Manual (together with any 

relevant associated materials, e.g. Safety Guidelines, Maintenance Manual, etc.); and (ii) 
10 

the PIC will inspect and test the fuselage, control surfaces/linkages, propulsion systems 

and radio control systems for proper condition and operation prior to each flight. 

We note that the UAS(s) at issue (i) are very limited in size, (ii) carry only a small payload 

(camera and powered servo mount), and (iii) will operate only in limited and 

predetermined areas and environments, under VLOS conditions, and for brief periods of 

time. Should mechanical issues nevertheless arise, the UAS can land immediately, and 

will be operating at no higher than 400 feet AGL in any event. Applicant/PIC will ensure 

that the UAS is in proper working order and will perform any required maintenance 

prior to beginning flight operations. 

N. NOTICE FOR PUBLICATION IN FEDERAL REGISTER 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should the FAA determine that such publication is necessary: 

Applicant seeks an exemption from the following rules: 14 CFR Part 21; 

14 CFR 45.23(b); 14 CFR 61.113(a)&(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 

14 CFR 91.103(b); 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203(a)&(b); 14 CFR 91.205(b)(3)&(4); 14 CFR 91.215; 

14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1)&(2); 14 CFR 

91.417(a)&(b), to facilitate commercial operation of a small unmanned 

vehicle (55 lbs or less) in filmmaking, cinematography and videography.

O. APPLICABILITY OF EXEMPTION OUTSIDE THE UNITED STATES 

While most of Applicant's operations currently occur within the United States proper, 

Applicant has in the past, and does from time to time, accept and perform film projects 

in non-US jurisdictions. Applicant may therefore wish to exercise the privileges of 

exemption requested hereunder outside the US in such cases. All required rules and 

regulations will be followed should this occur. 

* * * * * 

CONCLUSION

Approval of the requested exemption allowing for Applicant's commercial operations of 

the scheduled sUAS(s) in the filmmaking, cinematography and videography industry, 

conducted under circumstances and subject to reasonable restrictions as set forth 

herein, and/or as otherwise established by the FAA, (i) will provide (at least) an 

equivalent level of safety sufficient to support grant of the exemptions requested herein 

(i) may actually enhance safety by, e.g., reducing risk to conventional manned aircraft 

flight crews, uninvolved bystanders, property, the environment and the public at large, 

and (iii) is therefore manifestly in the public interest. 
11 

We respectfully submit that our request as set forth in this letter falls well within and 

satisfies the criteria provided in Section 333 of the Reform Act of 2012 -- size, weight, 

speed, operating capabilities, operation within visual line of sight and absence of 

national security concerns (inter alia) -- and hence provides more than adequate 

justification for the grant of the requested exemptions to allow for commercial 

operation of Applicant’s UAS(s) in the filmmaking, cinematography and videography 

industry. 

Sincerely, 

Terry L. Thomas, Esq. 

Thomas Legal Solutions 

Counsel for Spirit of Space, LLC 

cc: Adam Goss, Principal, Spirit of Space, LLC 

 Michael Marianek, Principal, Spirit of Space, LLC 

 
12 

EXHIBIT A

UNMANNED AIRCRAFT SYSTEMS 

FOR WHICH EXEMPTION IS REQUESTED 

• DJI Inspire 1