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March 5, 2016

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE

Washington, D.C. 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations.

Dear Sir or Madam:

Pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, Tripleffect Productions L.L.C., an owner and operator of small unmanned aircraft systems 

(sUASs), requests to be exempted from the Federal Aviation Regulations (“FARs”) listed below so that 

Tripleffect Productions L.L.C., may safely and legally operate small ultra-lightweight unmanned aircraft 

systems (“sUASs”) in the national airspace (NAS) regulated by the Federal Aviation Administration 

(“FAA”).

Following exemption and approval by the FAA, Tripleffect Productions L.L.C. will be responsible for the

Pilot in Command (PIC) of a professionally built, camera-equipped DJI S1000, DJI s900, DJI Inspire 1, 

DJI Matrice 100, DJI Phantom 3 Professional, DJI Phantom 2 and Yuneec Tornado H920 sUAS for the 

following applications: closed-set film operations for the motion picture, television and commercial 

productions, on-location film operations in controlled settings on private land or with property permission, 

augmentation of real-estate listing, mapping, agricultural crop surveillance, aerial inspections, data 

collection videos only with express permission of the property owner; and the creation of visual and 

topographical layout videos for state and local agencies, educational organizations, agricultural 

inspections or building and construction zone inspections, provided that such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333.

Granting exemption to Tripleffect Productions L.L.C. would permit the above specified operation of ultra

lightweight sUASs in the NAS with limited, tightly controlled, predetermined flight plans away from the 

general public, airports, heliports, motorways or any restricted airspace. Granting a request for Tripleffect

Productions L.L.C. complies with the Secretary of Transportation’s (FAA Administrator’s) instructions to 

integrate sUASs into the national airspace system, as well as to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of UAS's for real estate/realtor purposes, educational videos, search and 

rescue, land/trusts inspections, agricultural field monitoring, film/video productions, closed-set motion 

picture film, television operation and architectural structural inspections and to aid private, state and local 

agencies. Tripleffect Productions L.L.C. will ensure enhanced public safety by conducting operations in 

compliance with the specific safety protocols and regulations established by the FAA. Additionally, 

seamlessly integrating sUASs into the NAS will increase community awareness to the benefits of the 

sUAS industry. Increased awareness and education will reveal the positive role in which the sUAS 

industry can play in local communities while increasing safety.

I. Contact Information:

Tripleffect Productions L.L.C.

C/O: Brian Graf or Ross Wilson

Address: 157 6th street southwest

 Alabaster, Alabama 35007

Phone: 205-267-9224

Email: tripleffectllc@gmail.com
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II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Tripleffect

Productions L.LC. Requests Exemption are:

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 submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in the national airspace (NAS) before completion of the rule making 

required under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which type of sUASs do not create a hazard to users of the NAS or the public or pose a threat 

to national security. If the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333 (c) (emphasis added). 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, that 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 in the public interest. 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). 

III. The Extent of relief Tripleffect Productions L.L.C. Seeks and the Reason Tripleffect Productions 

L.L.C. Seeks Such Relief:

This exemption application is submitted on behalf of Tripleffect Productions L.L.C., in accordance with the 

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to 

prevent Tripleffect Productions L.L.C., Incorporated, predetermined commercial cinematic, academic and 

other flight operations within the NAS. The Reform Act in Section 332 provides for such integration of civil

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. 

Tripleffect Productions L.L.C. will be operating, ultra-lightweight sUASs that meet the definition of “small 

unmanned aircraft” as defined in Section 331 and, therefore the integration of such sUASs are expressly 

contemplated by the Reform Act.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates:

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

size and limited operating area associated with the aircraft to be utilized by the 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 the proximity to airports and 

populated areas of the particular sUAS. In all cases, an analysis of these 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 safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be 

operated hereunder is 55 lbs. or less fully loaded, carries neither a pilot nor passenger, carries no 

explosive materials or flammable liquid fuels, and operates exclusively within a secured area. 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 requirements, to provide security

for the area of operation as is now done with conventional filming. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil aircraft operated in connection with 

motion picture and television production, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat 

to national security posed by the sUAS due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability 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 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 the sUAS will have 

no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the 

cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the 

sUAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer, and others working with the sUAS will see 

the identification of the sUAS as “Experimental”. The FAA has issued the following exemptions to this 

regulation as Exemption Numbers 10700,8738, 10167 and 10167A.

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have no less than 40 hours of flight time with the 

specific sUAS equipment Tripleffect Productions L.L.C. operates. The experience of the PIC will be 

certified by Tripleffect Productions L.L.C. through background checks and, if necessary, testing.

Tripleffect Productions L.L.C. will maintain flight logs of all PICs it employs, and provide full transparency 

to the FAA regarding the logs and records of these PICs. The risks associated with the operation of the 

sUAS are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the sUAS by a PIC meeting the standards of Tripleffect 

Productions L.L.C. (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) 

& (b). Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no persons on board. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance. Currently, there are no pilot licenses that are specific for UAS operators, and 

no current FAA sanctioned pilot license of any type requires training with, and knowledge of, UAS 

equipment greater than the requirements Tripleffect Productions L.L.C. uses to certify its PICs. Therefore, 

the requirement of any available FAA sanctioned pilot license to operate a sUAS does not make
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14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command: (continued)

a PIC a more competent operator than one meeting the requirements of Tripleffect Productions L.L.C.

Our company hopes the FAA develops a new Pilot License specific for UAS and sUAS commercial

operation, one that sets high standards on the quality of pilots and increases the professionalism of our 

emerging industry. If the FAA does this, Tripleffect Productions L.L.C. PIC’s will file for these licenses. 

Our company would also be happy to work with the FAA to help develop the standards for new licenses, 

and any other regulations the FAA is developing for UAS operation.

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness 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 level of safety will 

be provided.

Tripleffect Productions L.L.C. Summarized Safety Checklists:

Aircraft: All adjustment points will be checked for tightness; all motors and props will be inspected; all 

wiring will be double checked; all systems will be powered up and checked for errors.

Battery: Confirmation will be made that batteries are fully charged and installed/connected properly.

Calibration: Pre-flight motor/gyro calibration followed by confirmation of no errors with the flight and 

navigation systems.

Compass Calibration: compass will be calibrated at each new location as per manufacturer’s protocols.

Transmitter: Confirm radio transmitter has sufficient charge, and is both working properly and receiving 

telemetry from the sUAS; confirm all switches are in pre-flight mode.

Surroundings/Flight Area: Conduct one last visual inspection of the take-off surroundings and area of 

airspace sUAS will be operating in. Confirm all people in the surrounding areas are associated with the 

filming being done.

Take-off Announcement: Before motors are started the PIC will announce to a designated 

Representative (person of authority) of the film crew that sUAS is ready to take-off. Only after the 

Representative has notified all persons within the surrounding areas, and confirmed to PIC that they have 

clearance to lift-off, will the motors be started and the sUAS will conduct its operation.

Test Flight: A test flight will be conducted: after any disassembly/reassembly; after replacement of any 

motors or flight electronics; after any pre-flight or in flight equipment errors that occur not resulting from 

environmental conditions; very first thing of any commercial operations day before filming 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 Aircraft Flight Manual in the Aircraft:

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For 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. The sUAS, given its size and configuration has no ability or 

place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but 

because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety 

will be maintained by keeping the flight manual at the ground control point where the PIC flying the sUAS 

will have immediate access to it. The FAA has issued the following exemptions to this regulation: 
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14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft: (continued)

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700. 

14 C.F.R. § 91.103: Preflight action:

This regulation requires each pilot in command to take certain actions before flight to ensure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing 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 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. sUASs and remotely 

piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished

through the use of a control box that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent 

level of safety is provided by the fact that 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 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 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 planned, an exemption 

may be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 

400 feet AGL with the exception that in circumstances where the sUAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above 

the highest point on the structure. It will however be operated in a restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained consent. The 

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

location where it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

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

This 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 be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight.
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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 battery powering the sUAS 

provides no more than 30 minutes of powered flight. 14 C.F.R. § 91.151, sUAS flights would not be 

possible due to the reserve requirement being equal to the maximum flight time. Given the limitations on 

the sUASs proposed flight area and the location 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

exemption from 14 C.F.R. § 91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 

(allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating 

the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151 (a)was intended to alleviate given the size and speed 

of the small UAS. Additionally, the limitations created by this requirement for sUAS flights would 

essentially make null any utility for which the exemption will be granted. Applicant believes that an 

equivalent level of safety can be achieved by limiting flights to 18 minutes or 30% of battery power—

whichever happens first. This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, and 10808.

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

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An 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 sUAS 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. An equivalent level of safety will be achieved by 

keeping these documents at the ground control point where the pilot flying the sUAS will have immediate 

access to them, to the extent they are applicable to the sUAS. 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.

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 “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 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance and inspections will be done in accordance with the sUAS Manufacturer's 

Manual, and will be performed by employees of Tripleffect Productions L.L.C., following the guidelines 

and practices provided to us by the sUAS Manufacturer. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and 

will be operating from no higher than 400 feet AGL. The PIC will ensure that the sUAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The 

PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. Additionally, Tripleffect Productions L.L.C., has realized 

the amazing benefits sUAS equipment can provide to the film and television industries. It not only 

provides new cinematography capabilities, but also increased safety over current and past practices that 

used larger and more dangerous equipment. Our company wants to have the highest levels of safety and 

professionalism, and one thing essential to this is achieving a path to 
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14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections: (continued)

commercial licensing with the FAA. We believe this will help reduce unsafe practices, discourage 

improper uses, and improve public perception. The commercial manufacturer 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 creating regulations that will allow incorporation of UAS devices into our 

country's airspace for commercial use.

IV. Reasons Why Tripleffect Productions L.L.C. Exemption Will Not Adversely Affect Safety Or

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the current regulatory structure because the 

proposed operations are conducted in limited areas with predetermined flight paths under the permission 

of the property owner or property representative.

These limitations and conditions to which Tripleffect Productions L.L.C. agrees to be bound when

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh no more than 55 lbs. with payload.

2. Flights will be operated within line of sight (VLOS) of the pilot in command (PIC) or visual observer 

(VO).

3. Maximum total flight time for each operational flight will be 18 minutes or at 30% battery power reserve 

should that occur prior to the 18-minute limit. PIC will use audible timer alert upon depletion of time 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 platform from which filming is planned. If a structure being filmed or photographed has a 

height which exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the highest point of

that structure.

5. Minimum crew for each operation will consist of the sUAS PIC, and the Visual Observer.

6. sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 40 hours of logged flight 

time with the specific sUAS equipment Tripleffect Productions L.L.C. operates. The experience of the PIC 

will be certified by Tripleffect Productions L.L.C. through background checks and, if necessary, testing. In 

addition, Tripleffect Productions L.L.C. will maintain flight logs of all PICs it employs, and provide full 

transparency to the FAA regarding the logs and records of these PICs.

7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, 

vehicles, vessels, or people not associated with the operation or who have not signed a waiver in 

advance of the operation.

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production 

activities. It will be mandatory that all personnel involved with the operational duties of the flight within the 

boundaries of the 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 appropriate local Flight Standards District Office.

10. The operator will obtain the consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced 

to 30 feet based upon an equivalent 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 operation of the specific sUAS equipment used 

by Tripleffect Productions L.L.C. and received up-to-date information on the particular sUAS to be 

operated.

12. Visual Observer and PIC will at all times be able to communicate by voice, or radio.

13. Written and/or oral permission from the relevant property holders or property representatives will be 

obtained.

14. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions,

including local law enforcement, fire or other appropriate government agencies.
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IV. Reasons Why Tripleffect Productions L.L.C. Exemption Will Not Adversely Affect Safety Or

How The Exemption Will Provide a Level of Safety at Least Equal to Existing Rule: (continued)

15. If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will have the 

capability to return to a pre-determined location within the Security Perimeter and land autonomously.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

Tripleffect Productions L.L.C. will perform standardized maintenance scheduled checks to ensure proper 

flight conditions of sUASs will include:

After 40 hours of flight:

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary.

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary.

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test 

flights before conducting commercial work.

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion 

of the rule making required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the following:

• 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.

Reform Act § 333 If the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333 (c) 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, that 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 in the public interest. 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). Tripleffect Productions L.L.C. sUASs are 

rotorcraft, weighing 55 or fewer lbs. including payload. They operate, under normal conditions at a speed 

of no more than 40 knots and have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in line of sight and will operate only within a predetermined and 

closed off property area under the permission of the property representative. Such operations will ensure 

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 sUASs involved and the restricted, controlled

environment within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also, due to the size of the sUASs and the 

restricted areas in which the relevant sUASs will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and commercial 

videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the 

applicant respectfully requests that the FAA grant the requested exemption without delay.
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V. How granting Tripleffect Productions L.L.C. Exemption will Benefit Public as a Whole:

Given the above stated evidence, procedure, and precautions operating sUASs commercially for the 

purposes of aerial photography and videography, mapping, agricultural crop surveillance, aerial 

inspections, data collection, augmented real estate listings, commercial videos and other work related to 

aerial photography will ultimately be in the public interest. These operations, when executed with 

prudence, will exceed the current level of safety as the regulations from which exemption is sought. 

sUAS operations will allow greater access to commercial aerial services that were not previously 

economically feasible for private, public, local and national principalities. This will provide a much needed 

economic uplift to the community and hence the public. sUAS operations are associated with less risk of 

collateral damage to persons and property while limiting disruptive noise pollution associated with low 

altitude aviation operations.

VI. Summary

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

Register, should it be determined that publication is needed. Applicant seeks an exemption from the 

following rules:

 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)
10

VI. Summary (continued)

Specifically, Tripleffect Productions L.L.C. is seeking 333 exemption for closed-set film operations for film 

and television productions, on-location film or television operations on private land or with property 

permission; aerial video support for films and commercials in controlled environments; augmentation of 

real-estate listing videos; and the creation of visual and topographical layout videos for state and local 

agencies, educational organizations, agricultural inspections or building and construction zone 

inspections. The sUASs will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. The operation of small UASs, weighing less than 55 lbs., 

conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the requirements of 

Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to 

the ground, and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and people. All flights will 

occur over private or controlled access property with the property representative or owner’s prior consent 

and knowledge. Filming will be of people who have also consented to being filmed or otherwise have

agreed to be in the area where filming will take place. All flights will occur in accordance with any state or 

local laws regarding privacy. Satisfaction of the criteria provided in Section 333 of the Reform Act of 

2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant’s sUAS equipment in the mapping, 

agricultural crop surveillance, aerial inspections, data collection motion picture, television, and 

commercial production industry.

Respectfully submitted,

Tripleffect Productions L.L.C.

C/O Brian Graf or Ross Wilson

Address: 157 6th street southwest

 Alabaster, Alabama 35007

Phone: 205-267-9224

Email: tripleffectllc@gmail.com
11

Appendix A – List of Unmanned Aircraft Systems UAS

Make & Model

DJI S1000

http://download.dji-innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

DJI s900

http://www.manualsdir.com/manuals/585906/dji-s900.html?page=30

DJI Inspire 1

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

DJI Matrice 100

http://download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf

DJI Phantom 3 Professional

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

DJI Phantom 2

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf

Yuneec H920 Industry

http://www.yuneec.com/download/manuals/h920_industry_user_manual_(st24)_v1.0.pdf

(CTRL + Link to follow designated links)

If there are any questions or more information needed, please contact:

Tripleffect Productions L.L.C.

C/O Brian Graf or Ross Wilson

Address: 157 6th street southwest

 Alabaster, Alabama 35007

Phone: 205-267-9224

Email: tripleffectllc@gmail.com