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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 th e 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 Adminis tration (“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, DJ I Phantom 3 P rofessional

, 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 pro perty 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 st ate 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 re quired 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, airport s, 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 structur a l inspections and to aid private, state and local agencies . Tripleffect Productions L.L.C. will ensure enhanced public s afety 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. Increase d 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 6 th 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

Production s L.LC. R equests 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 Product ions 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

unman ned 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 requireme nts 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)

si ze 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, up on 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 cri teria 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 ai rworthiness 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 exclu sively 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 o f 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 operat or 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 applicab le. 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 letter ing 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 Privileg es 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 operatio ns 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 back ground 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 p resent 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 fli ghts 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 requir ements 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 Privileg es and Limitations: Pilot in Command : (continued)

a PIC a more competent operator than one meeting the requirements of Tripleffect Produc tions 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, Trip leffect Production s 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): C ivil 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: Con d uct 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 a nnounce 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, wi ll 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 tha t 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): Civ il 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 i n 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 ai rcraft, 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 fl ying 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): Civ il 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 r egulation 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 includ ing 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 (e xcept 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 a ircraft. 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 prescrib ed 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 exem ption 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 co nsent. 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 n otice 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 he rein 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 w ill 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 cruisin g 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 conditi ons 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 a fter 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

p ossible due to the reserve requirement being equal to the maximum flight time. Given the li mitations 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 owne rs 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% o f 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 operati ng 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 fl ying 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, 9 797A, 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 sha ll 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 onl y 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 re quired maintenance, and keep a log of any maintenance performed

. T he 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. Additional ly

, 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 practice s, discourage improper uses, and improve public perception. The commercial manufacture r 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 E xisting 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 o f 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 al titude 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 t he highest point o f

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 o f 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 loca l 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 b ased 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.

1 2 . Visual Observer and PIC will at all times be able to communicate by voice, or radio.

1 3 . Written and/or oral permission from the relevant propert y holders or property representatives will be

obtained.

1 4 . 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. E xemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety at Least Equal to Existing Rule: (continu ed )

1 5 . 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.

1 6 . 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 exemptio n 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 nation al 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 o f 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 requiremen t 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 Ad ministrator 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 Production s 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 sU ASs 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 envir onmental 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 gran t 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 photogra phy 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, pub lic, 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 poll ution 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 determ ined 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 Production s L.L.C. is seeking 333 exemption for closed

- set fil m 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, weigh ing 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 t han 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 criteri a 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 g rant 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

.



### Res pectfully submitted,

Tripleffect Productions L.L.C.

C/O Brian Graf or Ross Wilson

Address: 157 6 th 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.dji

innovations.com/downloads/ph antom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf



### DJI Phantom 2 http://download.dji

innovations.com/downloads/phantom_2/en/PHANTOM2_User_Ma nual_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 6 th street southwest

Alabaster, Alabama 35007

Phone: 205

- 267

- 9224 Email: tripleffectllc@gmail.com