Eric Hunter

Camera Clay LLC

116 Pinnacle Drive

New Braunfels, Texas 78130

hireme@erichunterdp.com

January 14, 2016

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Ave, SE Washington, DC 20590

RE: CAMERA CLAY, LLC

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE

CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION

OF Freefly Alta UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)
SUMMARY

CAMERA CLAY LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b),

to operate an Unmanned Aircraft System (Freefly Alta) ​pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit CAMERA CLAY LLC

to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial

video and photography of construction sites, residential and commercial real estate, civil

landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

CAMERA CLAY LLC has provided their clients (including private sector businesses and

non­profits, along with local state and federal agencies) with expertise and knowledge in video

and multimedia marketing, advertising, public relations and training using advanced

technologies and solutions. CAMERA CLAY LLC has worked on hundreds of productions over

the past 6 years in various locations with a perfect safety record. We have supplied our clients

aerial video and photography using commercial aircraft. The objective of CAMERA CLAY LLC

and our Unmanned Aircraft System (Freefly Alta) ​aerial operations is to provide a more

affordable, high­quality production system for a variety of governmental, commercial, public, and

residential uses, specifically targeting

● Construction sites before and after

● Appraisals

● Real­estate marketing

● Economic development

● Civic landmarks

● Special event coverage

● Private and governmental training

I have safely flown Cessna 172’s as well as small RC electric quadcopters for approximately 7

years, without incident.

BACKGROUND

Unmanned Aircraft Systems: Freefly Alta, UAS

CAMERA CLAY LLC seeks an exemption to operate Freefly Alta system for compensation or

hire within the NAS. The Freefly Alta is vertical takeoff and landing (VTOL) Unmanned Aircraft

(UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems.

The Freefly Alta has a maximum gross weight of approximately 29.9 lb. while having a diagonal

dimension of 39.4”, a maximum speed of approximately 85’fps and a maximum flying height of

400'. The Freefly Alta is equipped with six main rotors; driven by Lithium Polymer battery

powered electric motors.
The Freefly Alta that will be operated by CAMERA CLAY LLC will be registered in accordance

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration,

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, CAMERA CLAY LLC, pursuant to the provisions of the Federal Aviation Regulations

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333,

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to

commercially operate the Freefly Alta, UAS in the National Airspace System (NAS), and for an

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, CAMERA CLAY LLC operation of the Freefly Alta UAS

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, CAMERA CLAY LLC requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

CAMERA CLAY LLC submits that the requested relief is proper since an equivalent level of

safety will be ensured. CAMERA CLAY LLC will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance

Log, and the Freefly Alta Instruction Manual). Furthermore, CAMERA CLAY LLC will document

and maintain all maintenance records for the Freefly Alta UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by CAMERA CLAY LLC to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an

airman medical certificate, and who has demonstrated, by meeting minimum flight­ hour and

currency requirements, that the PIC is able to safely operate the Freefly Alta UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

CAMERA CLAY LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the Freefly Alta UAS do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. As such, CAMERA CLAY LLC submits that they will ensure the

Freefly Alta UAS is in an airworthy condition, prior to every flight, by determining that the UAS

are in compliance with the operating documents (i.e., Monthly Maintenance Log, and Freefly

Alta Instruction Manual), and that the aircraft are in a condition for safe flight.

CAMERA CLAY LLC also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the Freefly Alta UAS will not have a typical barometric altimeter onboard.

However, altitude information of the Freefly Alta UAS will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with CAMERA CLAY LLC’s operation of the Freefly Alta UAS within
visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, CAMERA CLAY LLC seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. CAMERA CLAY LLC submits

that safety will not be affected by operation of the Freefly Alta UAS during daylight hours in

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly for a total duration of approximately 20 minutes. Battery power indicators are also

able to show exactly how much battery power is left, as well as how much time is needed to

return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, CAMERA CLAY LLC provides the following information in

support of its petition for exemption:

A.​Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Eric Hunter

Camera Clay LLC

116 Pinnacle Drive

New Braunfels TX 78130

(727) 244­7583

hireme@erichunterdp.com

B. The Specific Sections Of 14 C.F.R. From Which CAMERA CLAY LLC​Seeks Exemption.

1. CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Section 61.113(a)

And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections

(a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an

aircraft that is carrying passengers or property for compensation or hire; nor may that person,

for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3.​CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that

aircraft, as the case may be, by reference to an altimeter that is set, when operating­­

(1) Below 18,000 feet MSL, to­­
(i) The current reported altimeter setting of a station along the route and within 100 nautical

miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or

an appropriate altimeter setting available before departure.

4.​CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

5.​CAMERA CLAY LLC​Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner

or operator of an aircraft—

(a) 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[.]

6. CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless­­

(1) It has been approved for return to service by a person authorized under § 43.7 of this

chapter[.]

7. CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had ­­

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for

return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this chapter.

8. CAMERA CLAY LLC​Seeks Exemption From The Requirements Of Sections 91.417(a)

And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner

or operator shall keep the following records for the periods specified in paragraph (b) of this

section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100­hour, annual, progressive, and other required or approved inspections, as appropriate, for

each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an

aircraft. The records must include­­

(i) A description (or reference to data acceptable to the Administrator) of the work performed;

and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life­limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including,

for each, the method of compliance, the AD or safety directive number and revision date. If the

AD or safety directive involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred

with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter

shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief CAMERA CLAY LLC​Seeks And The Reason CAMERA CLAY LLC

Seeks The Relief.

1. Extent Of Relief CAMERA CLAY LLC​Seeks And The Reason CAMERA CLAY LLC

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher

level certificate, as well as a current and valid airman medical certificate, and who has met
certain flight­hour and currency requirements, to conduct the proposed UAS flight operations for

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, CAMERA CLAY LLC submits that an equivalent level of safety will

be maintained because no PIC will be allowed to operate the Freefly Alta UAS unless that PIC

has met certain flight­hour and currency requirements, demonstrating that the PIC is able to

safely operate either the Freefly Alta UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency maneuvers, as

well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, CAMERA CLAY LLC submits that all flights of the Freefly Alta UAS, conducted by the

PIC pursuant to the grant of this Petition: (1) will be incidental to CAMERA CLAY LLC’s

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief CAMERA CLAY LLC​Seeks And The Reason CAMERA CLAY LLC

Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow CAMERA CLAY LLC to determine that the Freefly Alta UAS are in airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., CAMERA CLAY LLC Aerial Operations Manual, Monthly Maintenance Log, and

Freefly Alta Instruction Manual).

CAMERA CLAY LLC seeks the requested relief because the Freefly Alta UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CAMERA

CLAY LLC will ensure that the Freefly Alta UAS is in airworthy condition based upon its

compliance with the operating documents (i.e., Monthly Maintenance Log, and Freefly Alta) prior

to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in

the conditions and limitations below.

3. Extent Of Relief CAMERA CLAY LLC Seeks And The Reason CAMERA CLAY LLC

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations

of the Freefly Alta UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio

communications telemetry data link to downlink altitude information from the UA to the PIC at

the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), CAMERA CLAY LLC seeks the requested relief because the Freefly Alta UA’s altimeter

may be set on the ground to zero feet AGL, rather than the local barometric pressure or field

altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As
more fully set forth herein, an equivalent level of safety will be maintained since the Freefly Alta

UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically

ensures that a ground level pressure setting will be established prior to each flight, and provides

the PIC with altitude information of the UA on the heads­up display of the GCS.

4. Extent Of Relief CAMERA CLAY LLC Seeks And The Reason CAMERA CLAY LLC

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered Freefly Alta UAS during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a

total duration of 20 minutes. CAMERA CLAY LLC seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered Freefly Alta

UAS will severely constrain the practicality of any aerial video or still photo flight operations that

CAMERA CLAY LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Freefly Alta UAS, the Freefly

Alta operating documents, and CAMERA CLAY LLC’s proposed operating limitations, ensure

that CAMERA CLAY LLC will safely operate the battery powered Freefly Alta UAS during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with

enough battery power to fly for a total duration of 20 minutes.

5. Extent Of Relief CAMERA CLAY LLC Seeks And The Reason CAMERA CLAY LLC

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &

(b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to

aircraft with an airworthiness certificate, CAMERA CLAY LLC requests relief from these

Sections because the Freefly Alta UAS do not require airworthiness certificates. As set forth

more fully below, the Freefly Alta UAS meet the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly, CAMERA CLAY LLC will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

CAMERA CLAY LLC Aerial Operations Manual, Monthly Maintenance Log, and Freefly Alta

Instruction Manual). Furthermore, CAMERA CLAY LLC will document and maintain all

maintenance records for the Freefly Alta UAS.

D. The Reasons Why Granting CAMERA CLAY LLC Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing CAMERA CLAY LLC to

safely, efficiently, and economically perform aerial video and photography of construction sites,

real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the Freefly Alta UAS will decrease congestion of the NAS, reduce pollution,

and provide significant benefits to the economy. Notably, the benefits of CAMERA CLAY LLC’s

proposed operation of the Freefly Alta UAS will be realized without implicating any privacy

issues.
1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Freefly Alta UAS are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a Freefly Alta UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The Freefly Alta UAS

does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft

conducting aerial video and photography missions would result in fewer aircraft that must be

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of

flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Freefly Alta UAS.

Conducting aerial acquisitions with the Freefly Alta UAS, instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels of air and noise pollution generated during

traditional aerial video and still photography flight operations. By using battery power and

electric motors, the Freefly Alta UAS produces no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine

aircraft that are typically utilized for aerial video and photography, while burning approximately

20­30 gallons per hour of leaded aviation fuel. The Freefly Alta UAS, while reducing the carbon

footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by

battery powered electric motors, rather than an internal combustion engine.

By using the Freefly Alta UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the Freefly Alta UAS (weighing

approximately 29.9 pounds at their maximum gross weight with diagonal dimension of 39.4

inches, and with no fuel on board), has less physical potential for collateral damage to life and

property on the ground, and in the air, compared to the manned aircraft that typically conduct

similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The Freefly Alta UAS Will

Benefit The Economy.

In addition to being safe and efficient, the Freefly Alta UAS are also an economical alternative to

using manned aircraft to conduct similar aerial operations. As such, operation of the Freefly Alta

UAS will allow United States based companies, like CAMERA CLAY LLC, to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology
in order to remain competitive. Operating the battery powered Freefly Alta UAS is one such

technology that not only allows companies greater operational flexibility compared to manned

aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.

By operating the Freefly Alta UAS, companies such as CAMERA CLAY LLC, can remain

competitive and profitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial

performance of U.S. companies, through commercial use of the Freefly Alta UAS, provides a

stable workforce that increases consumer spending; improves local, state, and federal tax

revenues; and allows companies to invest in research and development in order to remain

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

CAMERA CLAY LLC’s proposed operation of the Freefly Alta UAS will not implicate any privacy

issues. Specifically, the Freefly Alta UAS will be operated only in compliance with operating

documents (i.e., CAMERA CLAY LLC Aerial Operations Manual, Monthly Maintenance Log, and

Freefly Alta Instruction Manual) which requires property owner involvement as well as local law

enforcement notification, and in accordance with the Federal Aviation Regulations, including the

minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The

Rule From Which CAMERA CLAY LLC Seeks Exemption.

1. Reasons Why The Freefly Alta UAS Meet The Conditions Of The FAA Modernization

and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, CAMERA CLAY LLC’s operation of the Freefly Alta UAS

meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states

the following, in part:

(a) In General.­­Notwithstanding any other requirement of this subtitle, and not later than 180

days after the date of enactment of this Act, the Secretary of Transportation shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system before

completion of the plan and rulemaking required by section 332 of this Act or the guidance

required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.­­In making the determination under subsection

(a), the Secretary shall determine, at a minimum­­
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed,

operational capability, proximity to airports and populated areas, and operation within visual line

of sight do not create a hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

(c) Requirements for Safe Operation.­­If the Secretary determines under this section that certain

unmanned aircraft systems may operate safely in the national airspace system, the Secretary

shall establish requirements for the safe operation of such aircraft systems in the national

airspace system.

In seeking this exemption, CAMERA CLAY LLC submits that the Freefly Alta UAS can operate

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of

the Freefly Alta UAS; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The Freefly Alta UAS Demonstrate Its Safe Characteristics.

The Freefly Alta UAS does not create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The Freefly Alta UAS.

The technical specifications of the Freefly Alta UAS are set forth by the Freefly Alta User

Manual, attached hereto as Appendix A.

ii. The Freefly Alta UAS Global Positioning Modes Enable The UAS To Remain Within A

Defined Operational Area.

The Freefly Alta UAS may be operated in both manual and global positioning flight modes. A

complete description of the flight and navigational modes of the Freefly Alta UAS is provided at

pages 67 of the Freefly Alta User Manual attached hereto as Appendix A.

iii. The Freefly Alta UAS Are Designed For Automatic Return To Home Point Or Hover In

The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Freefly Alta UAS will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the Freefly Alta UAS does not reacquire control link data from the

GCS, the UAS will assume that the Control Link is lost and the will return to the home position

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the Freefly Alta UAS are set forth at pages

68 through 69 of the Freefly Alta User Manual, attached hereto as Appendix A.

iv. The Freefly Alta Flight Parameters.

A complete description of the Freefly Alta flight control software is provided at pages 58 through

64 of the Freefly Alta User Manual. Freefly Alta User Manual is attached hereto as Appendix A.
b. Flight Operations Of Freefly Alta UAS Is Limited To The Line Of Sight Of A Certificated

Pilot in Command With A Safety Observer.

CAMERA CLAY LLC video production staff will be the only persons to act as a pilot in command

(PIC) of the Freefly Alta UAS. Additionally, a safety observer will assist him at all times during

flight time.

c. Flights Of Freefly Alta UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, CAMERA CLAY LLC proposes to commercially operate Freefly Alta

UAS for the special purpose of conducting aerial video and photography over certain areas of

United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft

described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum

gross weight: Freefly Alta Unmanned Aircraft Systems. Proposed operations of any other

aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose

of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL),

as indicated by the procedures specified in the operating documents unless a special request is

made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than corrective

lenses, as specified on the PIC’s FAA­issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be

able to communicate verbally at all times. Electronic messaging or texting is not permitted

during flight operations. The PIC must be designated before the flight and cannot transfer his or

her designation for the duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding

other air traffic and other ground based obstacles/obstructions and is not permitted to operate

the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. Otherwise, the operator must follow the

procedures as outlined in its operating documents. The operator may update or revise its
operating documents. It is the operator’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon request. The operator must also

present updated and revised documents if it petitions for extension or amendment to the grant

of exemption. If the operator determines that any update or revision would affect the basis upon

which the FAA granted the exemption, then the operator must petition for amendment to its

grant of exemption. The FAA’s UAS Integration Office (AFS­80) may be contacted if questions

arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft

is prohibited from operating until the necessary maintenance has been performed and the UAS

is found to be in a condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional

test flight. The PIC who conducts the functional test flight must make an entry in the aircraft

records.

12. The pre­flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the operating

documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements,

in accordance with the operating documents. Maintenance, inspection, alterations, and status of

replacement/overhaul component parts must be noted in the aircraft records, including total time

in service, description of work accomplished, and the signature of the authorized person

returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third­ class

medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles

and structures. PIC qualification flight hours must be logged in a manner consistent with 14

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under

the terms of the exemption. However, training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience­building flights, all

persons not essential for flight operations are considered nonparticipants, and the PIC must
operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at night is

required, a special request will be made at the FAA office closest to proposed area of

operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on

a current FAA­published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as

required by the operator’s COA. The letter of agreement with the airport management must be

made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined

location within the planned operating area and land or be recovered in accordance with the

operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing point

and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number,

registered in accordance with 14 C.F.R. part 47, and have identification (N­ Number) markings

in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control

of the UA must comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC

at the Ground Control Station of the UAS any time the UAS is operating. These documents

must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and

activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and

structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons leave

such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of

such vessels, vehicles or structures has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it does not

present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an

undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled­access property with permission

from the landowner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the operational area as defined by the applicable COA must be reported to the FAA's UAS

Integration Office (AFS­80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

CAMERA CLAY LLC submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Freefly Alta

UAS unless that PIC has demonstrated, by meeting minimum flight­hour and currency

requirements, that the PIC is able to safely operate the Freefly Alta UAS in a manner consistent

with the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering CAMERA CLAY LLC’s proposed area of operations, and the operating limitations

set forth­above; the parallel nature of private pilot aeronautical knowledge requirements to those

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills

necessary to safely operate the Freefly Alta UAS, CAMERA CLAY LLC submits that the

additional manned airmanship experience of a commercially certificated pilot would not correlate

to the airmanship skills necessary for CAMERA CLAY LLC’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138,

11150, 11153, 11156, 11158, 11159, 11160, 11161).

CAMERA CLAY LLC will not allow any PIC to operate the Freefly Alta UAS unless that PIC has

demonstrated, by meeting minimum flight­hour requirements or the Freefly Alta UAS training

and currency requirements, that the PIC is able to safely operate the Freefly Alta UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R.

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs

and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety

during CAMERA CLAY LLC’s proposed operations. The Administrator has held that prior

documented flight experience that was obtained in compliance with applicable regulations would

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot

including at least 10 hours logged as a UAS pilot with a multi­rotor UAS. Prior to operations

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption. For clarification, the FAA considers these minimum hour requirements to

be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10

hours of multi­rotor time and the 10 hours may be included in the total 25 hours of UAS

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum,

the flight­hour requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The

FAA also finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience­building flights can also be conducted under the grant of exemption to accomplish

the required flight time. During training, proficiency, and experience­building flights the PIC is

required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, CAMERA CLAY LLC will ensure safe operations by not allowing any PIC to

operate the Freefly Alta UAS unless that PIC has demonstrated, by meeting minimum flight­hour

and currency requirements, that the PIC is able to safely operate the Freefly Alta UAS in a

manner consistent with the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, CAMERA CLAY LLC will ensure that the Freefly Alta UAS is in an airworthy

condition based upon the UAS’s compliance with its operating documents and as stated in the

conditions and limitations herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the

altitude information of the Freefly Alta UAS will be provided to the PIC via GPS equipment and a

radio communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path and altitude. This altitude information, combined with CAMERA

CLAY LLC’s operation of the Freefly Alta UAS within visual line of sight, at or below 500 feet

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude

initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the Freefly Alta UAS; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, CAMERA CLAY LLC will ensure that it will safely operate the battery

powered Freefly Alta UAS during daylight hours in VFR conditions, with enough battery power

to fly for a total duration of 20 minutes.

Here, as in Exemption No. 11109, the technical specifications of the Freefly Alta UAS; the

limitations on the proposed flight operations; and the location of the proposed operations, will

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore,

safety will be ensured as the Freefly Alta UAS provide audible and visual warnings to the PIC at

the GCS when the UAS experiences low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% remaining battery

power. At the critically low battery level, the Freefly Alta UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of

the UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.
8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, CAMERA CLAY LLC submits that the equivalent level of safety with

regard to the regulatory maintenance and alteration requirements established by Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because

CAMERA CLAY LLC will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in

the operating documents (i.e., CAMERA CLAY LLC Aerial Operations Manual, Monthly

Maintenance Log, and Freefly Alta Instruction Manual). Furthermore, CAMERA CLAY LLC will

document and maintain all maintenance records for the Freefly Alta UAS.

Since the Freefly Alta UAS will be inspected as prescribed by the operating documents,

CAMERA CLAY LLC will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Freefly Alta User Manuals are attached

hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because CAMERA CLAY LLC

will use trained technicians to perform maintenance, alterations or preventive maintenance on

the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Freefly Alta UAS will

be performed by trained technicians. Maintenance will be documented and maintained utilizing

the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of CAMERA CLAY LLC’s proposed operating limitations, the operating

documents, and the technical aspects of the Freefly Alta UAS, CAMERA CLAY LLC submits

that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

granted relief specific to UAS in circumstances similar, in all material respects, to those

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080,

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,

11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, CAMERA CLAY LLC requests that the FAA

prescribe special conditions for the intended operation of the Freefly Alta UAS, which contain

such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) &
(b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b). Such special conditions will permit safe operation of the UAS for the limited purpose of

conducting aerial video and photography over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to

national security; and further, provides the authority for such UAS to operate without

airworthiness certification in accordance with any requirements that must be established for the

safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the Freefly Alta UAS, since the airworthiness regulations of 14 C.F.R.

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special

conditions and amendments thereto for the product. The special conditions are issued in

accordance with Part 11 of this chapter and contain such safety standards for the aircraft,

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent

to that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the Freefly Alta UAS,

which contain such safety standards that the Administrator finds necessary to establish a level

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which CAMERA CLAY LLC Seeks Exemption:

CAMERA CLAY LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption CAMERA CLAY LLC Seeks:

This exemption will permit CAMERA CLAY LLC to commercially operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial video and photography over certain areas of

the United States.

• Any Additional Information, Views, Or Arguments Available To Support

CAMERA CLAY LLC’s Request.

This Petition is made pursuant of the FAA Modernization and Reform Action of 2012 (Public

Law 112­95), which directs the Secretary of Transportation to determine if certain UAS may
operate safely in the NAS. As such, CAMERA CLAY LLC’s request for exemption may be

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, CAMERA CLAY LLC will operate the Freefly Alta UAS safely in

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat

to national security.

CONCLUSION

As set forth herein, CAMERA CLAY LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the Freefly Alta UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting aerial video and photography over certain areas of the United

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests

of the public, by allowing CAMERA CLAY LLC to safely, efficiently, and economically operate

the Freefly Alta UAS commercially within the NAS.

WHEREFORE​, in accordance with the Federal Aviation Regulations and the FAA Modernization

and Reform Act of 2012, Section 333, CAMERA CLAY LLC respectfully requests that the

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), and permit CAMERA CLAY LLC to operate the Freefly Alta UAS commercially

for the purpose of conducting aerial video and photography over certain areas of the United

States.

Dated: January 14, 2016

Respectfully submitted,

Eric Hunter

Camera Clay LLC

116 Pinnacle Drive

New Braunfels TX 78130

(727) 244­7583

hireme@erichunterdp.com

Appendix A – Freefly Alta User Manual