505 Fairway Dr

PO Box 1185 Tahoe City

, CA 96145 Tom@CloudD8ta.com

530 386 6677

April 21, 2016

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption No. 1 4248 ( January 8, 2016 ) Reg ulatory Docket No. FAA

- 2015

- 4863

Amendment to Thomas Jennings for Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

Dear Sir or Madam : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 1, Thomas Jennings , hereby submits the following amendment

to hi s Exemption granted on January 8, 2016

.

Thomas Jennings requests an amendment to his 333 exemption to include : 1. FAA a pproval to operate as CloudD8ta LLC.

2. FAA a pproval to use any ai rcraft identified on the List of Approved Unmanned Aerial Systems (UAS) under Section 333 at regulatory docket FAA

– 2007

– 3330 at www.regulations.gov

. 3. FAA approval to conduct Commercial UAS Operations for the purpose of UAS Training.

4. FAA approval to conduct Commercial UAS Operations for the purpose of filming

and film

- production related a ctivities (such as on set data collection or power transmission) on closed sets in both scripted and unscripted production in the motion picture, television, large format film, commercial advertisement, virtual reality, new media and digital industry.

For ease of use, this Amendment sets forth the heading of the applicable section of the January 8, 2016 Exemption, followed by a description of the addition or change to the

section.

Conditions and Limitations (Page 3 )Original Text: In this grant of exemp tion, Mr. Thomas Jennings is hereafter referred to as the operator.

New Amended Text: (Added: “ CloudD8ta LLC ”) In this grant of exemption, CloudD8ta LLC is hereafter referred to as the operator.

Conditions and Limitations (Page 3 )

Original Text:

1. Op erations authorized by this grant of exemption are limited to the 3D Robotics Aero

M, 3D Robotics Iris +, 3D Robotics Solo, DJI Flame Wheel F450, DJI Flame Wheel F550, DJI Inspire 1, DJI Matrice 100, and DJI Spreading Wings S1000 when weighing

less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

New Amended Text: (Added: “ List of Approved Unmanned Aerial Systems ”)

1. The operator is authorized by this grant of exemption to use any aircraft identified on the List of Approved Unmanned Aerial Systems (UAS) under Section 333 at regulatory

docket FAA

– 2007

– 3330 at www.regulations.gov, when weighing less than 55 pounds including payload. Proposed operations of any airc raft not on the list currently posted to the above docket will require a new petition or a petition to amend this exemption.

Our Decision (Page 2 )

Original Text:

In consideration of the foregoing, I find that a grant of exemption ........ to allow the peti tioner to operate a UAS to perform aerial data collection . This exemption is subject to

the conditions and limitations listed below.

New Amended Text : ( Added : “ and/or sUAS Training”)

In consideration of the for egoing, I find that a grant of exemption ........ to allow the petitioner to operate a UAS to perform aerial data collection and/or sUAS Training. This exemption is subject to the conditions and limitations listed below.

Our Decision (Page 2 )

Original Text:

In consideration of the foregoing, I find that a grant of exemption ........ to allow the petitioner to operate a UAS to perform aerial data collection . This exemption is subject to

the conditions and limitations listed below.New Amended Text : ( Added : “ and/or closed set motion picture and filming ”) In consideration of the foregoing, I find that a grant of exemption ........ to allow the petitioner to operate a UAS to perform aerial data collection and/or closed set m otion picture and filming . This exemption is subject to the conditions and limitations listed

below.

Conditions and Limitations (Page 3 )

Original Text:

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

New Amended Text: ( Deleted : “ not ”)

2. Operations for the purpose of closed

- set motion picture and television filming are permitted.

Thomas Jennings currently maintains an approved 333 exemption for aerial data

collection. Thomas Jennings requests an amendment to his 333 exemption to include FAA approval to conduct Commercial UAS Operations for the purpose of filming and

film

- production related activities (such as on set data collection or power transmission)

on closed sets in both scripted and uns cripted production in the motion picture, television, large format film, commercial advertisement, virtual reality, new media and digital industry. Included in this document are the items we seek relief from as well as the following attachments:

CloudD8ta

- Motion Picture and Television Operations Manual

CloudD8ta LLC

- DJI Inspire 1 User Manual

CloudD8ta LLC Thomas Jennings has extensive experience in UAS operations, with 15 years experience in the film industry and 1000 hours as a UAS pi lot

. He has worked for two years for Skycatch as a corporate trainer and consultant. Thomas Jenninngs ’s approved 333: EXEMPTION NO. 1 4248 REGULATORY

DOCKET NO. FAA

- 2015

- 4863

RELIEF REQUESTED

This is a petition to amend to my existing 333 / COA to include Closed Set filming. Our

Motion Picture and Television Operations Manual (attached) requests relief from the following, or amendments to approved relief as described below: 1. 14CFR § 61.113(a) Safety Observer, considered part of the aircrew by CloudD8ta

, may assist the PIC with visual search and line of sight responsibilities without the SOregulatory requirements of a PIC. 2. 14CFR § 91.119(c) consistent with FAA Order 8900.1 V3, C8, S1, p articipating persons, vehicles, and structures directly involved in the performan ce of actual filming. 2.1. Requesting flight operations conducted closer than 500 feet from participating

persons consenting to be involved and necessary for the filming production as specified

in the MPTOM. Non

- participating persons are not allo wed within 500 feet of the operating area with a reduction to 200 feet if an acceptable level of safety can be achieved and the Administrator has approved it.

2.2. CloudD8ta requests defined relief for a further reduction in UAS

- to

- non

- p articipants (human an d animal) who are safely inside an object such as an automobile, boat, ship,

train or covered moving object on land or water (or under water) from 500/200 feet to 50 feet while operating a medium

- weight UAS with a payload at or under 33.5 lbs. 2.2.1. Speci fically, CloudD8ta requests the waiver to operat e at 50 feet from those who

are near or a part of production but have not (such as cars passing by), can not (such as animals) or are unable to commit to participant status. The API will list the 50 foot
exempt ion as an option and with the reasons why the 50 foot separation is desired. 2.2.1.1. Examples of this 50 foot separation would be to film near a waterway such as those in Los Angeles where roads a bove are not blocked from cross traffic. The UAS

could safe ly pass under the bridge. Other examples: Aerials of a train passing over a bridge in a g orge, sledding events through a narrow pass led by animals, or wildlife observation in natural settings. 2.2.1.2. The primary reason to include reduced separation and over flight is that the human, animal or object has moderate protection from the structure (car, boat, etc. ) or they are not in the flight path vector in the unlikely event of catastrophic system failure. 2.2.2. Additional safety measures for 50 foot operati ons would be the reduced payload size (33.5 lbs maximum) and landing zone nets shaped to preclude overshooting a 50 foot mark. For example, a backstop in a baseball field. The 50 foot exclusion with a backstop or fenced zone (shaping where the 50’ exclusio n applies) is ample distance to separate non

- participants and participants from debris or systems experiencing a malfunction during the takeoff or landing phase. 2.2.2.1. Standard 500/200 feet of separation would be reduced to 50 feet due to closed set

si ze, non

- participants near an open se t, weather, terrain or lighting advantages. 3. 14CFR § 91.151(a) Fuel Requirements for Flight in VFR Conditions 3.1. Similar exemptions have been granted including Nos. 2689, 5745 and 10650. Similar

UAS relief has been g ranted in Exemption Nos. 8811, 10808 and 10673 for daytime,

VFR conditions.

3.2. CloudD8ta LLC UAS VLOS operations in controlled, closed

- set filming

environment will be restricted to 30 knots as suggested by the UA manual, returning to

land with 20 % or more power based on current operating conditions or a pre

- planned amount higher above 20% based on terrain, wind, vertical obstructions or other safety or

environmental factors. 4. 14CFR § 91.405(a) and (b) ///Already exempted by Exemption No 11825/// Maintenance Required:

Re

- iterating that CloudD8ta maintains and requests relief by adh ering to manufacturer

suggested maintenance documents with visual inspection of high

- stress parts after each flight and part replacement as suggested by manufacturer guida nce. CloudD8taoperations listed in 5. 14CFR § 91.407(a)(1) ///Already exempted by Exemption No 11 825/// Operating

documents will contain minimum inspection requirements and daily preflight inspection

for the UAS. 6. 14CFR § 91.409(a)(1) & (2) ///Already exe mpted by Exemption No 11825/// Operating

documents will contain minimum inspection requirements and daily preflight inspection

for the UAS. 7. 14CFR § 91.417(a) and (b) ///Already exempted by Exemption No 11825/// 8. 14CFR § 91.7(a) ///Already exe mpted by Exemption No 11825/// Clari fying that

CloudD8ta will operate only UAS systems approved through our COA / 333 exemption

or as indicated in the List of Approved Unmanned Aerial Systems (UAS) under Section 333 at regulatory docket FAA

– 2007

– 3330 at www.regulations.gov

. 9. ADDITIONAL RELIEF

- If there are additional e xemptions fou nd essential to closed

set film operations or common requests other than those requested above or those previously exempted in docket FAA

- 2015

- 0373 (listed in 9.1) we would appreciate your professional insight. 9.1....Pursuant to the authority c ontained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, CloudD8 ta LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.4 05(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data

collection. 10. The purpose of request 2.2 to maneuver in to 50 feet from non

- particip ating personnel / participating personnel w/ 33.5lb payload while non

- participants are in a transitory or protected position is because we believe sound judgment reduces and mitigates risk of collision significantly. By writing the FSDO on each API to confirm the 50’ exe mption, by exception and on a case by case basis, CloudD8ta believes safety will remain paramount while making the most of medium payload UAS. 10.1. Examples for API 50’ exemption: when there is a backsto p or net in between the

UAS and non

- participants or a UAS passing under an overpass while autos pass

overhead.

Questions or comments may be addressed to Thomas Jennings

, CloudD8ta LLC

Thomas Jennings CEO, CloudD8ta LLC tom@cloudd8ta.com

530 386 6677

Attachments:

CLOUDD8TA MOTION PICTURE AND TELEVISION OPERATIONS MANUAL .pdf DJI Inspire 1 User Manua l.pdf