“Petition for exemption/rulemaking” 

We are writing pursuant to the FAA Modernization and Reform Act of 20121 (the "Reform Act") and the 

procedures contained in 14 C.F.R. 11, to request that James Tiblier, a media entrepreneur an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed 

below so that we may operate its small unmanned aircraft I lightweight unmanned aircraft systems 

("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as long as 

such operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. The conditions identified and proposed by the applicant are 

drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver for Motion Picture, 

Television Filming, and Internet publication. 

As identified and described herein, James Tiblier and team is an experienced veteran in the broadcast 

and Internet production industry James Tiblier has been producing works delivering technical service 

applications for the broadcast industry for nearly five (5) years. James Tiblier has also been an avid R/C 

model flyer for over fifteen (15) years. James Tiblier is looking to grow his production service contracts 

with many entertainment multi-media conglomerates including; FOX Sports, NBC/Universal, CBS, 

Discovery Networks, and many more.

Our Team has been actively involved in the technical development of UAS/ UAV service applications to 

provide high definition film quality by aerial cinematography with small, unmanned aircraft and 

lightweight UASs. It is currently one of the many new and innovative teams that is developing advanced 

technical applications and abilities for future commercial service applications. We have equipped our 

small unmanned aircraft for aerial photography and cinematography, primarily for use in the television 

broadcast industry, and internet publications though given their stability and maneuverability, they may 

be used for other cinematography, by law enforcement personnel, search and rescue, and by other first 

responders.

This request would permit its operation of lightweight, unmanned (remotely controlled in line of sight) 

UASs in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, 

cordoned off locations and corresponding enhancements to current safety controls will allow 2 man 

teams with 1 drone operations. Safety parameters and new ones being implemented. As identified, 

similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. James Tiblier is currently using a client website 

application to monitor, evaluate and implement all aerial cinematography activities with a pre-flight 

safety and flight plan system. 

Granting James Tiblier this request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UASs into the national airspace system, but to " ... 

establish requirements for the safe operation of such aircraft systems [UASs] in the national airspace 

system" under Section 333(c) of the Reform Act. Further, James Tiblier will conduct its operations in 

compliance with the protocols described herein or as otherwise established by the FAA. 

James Tiblier requests the grant of an exemption allowing it to operate lightweight, remote controlled 

UAS's. The Specific Sections of Title 14 of the Code of Federal Regulations, James Tiblier are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a)(1); 14 CFR

409 (a)(2); and, 14 CFR 417 (a) & (b).
Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b)

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1);

91.409 (a) (2);91.417 (a) & (b). 

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated near 

airports or populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 

(a). Each of these items militates in favor of an exemption for James Tiblier

The reported UASs utilizes four counter-rotating propellers for extreme balance, control and stability. 

They each weigh less than 55 pounds, including cinematic or other equipment. Each of our small 

unmanned aircraft are designed to primarily hover in place and operate at less than a 50 knot maximum 

speed. They are capable of vertical and horizontal operations but operate only within the line of sight of 

the remote control pilot and his spotter. In addition to the remote control pilot, James Tiblier uses a 

spotter, such that, at minimum, 2 personnel govern the safe flight of an aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between eight and ten minutes. 

James Tiblier does not operate the UASs with less than twenty percent battery capacity. Safety systems 

in place include a GPS mode that allows pilot and spotter Services U ASs to hover in place if 

communication with the radio control pilot is lost and then slowly descend the UAS at twenty percent 

battery capacity. Further, the UAS is programmed, in some instances, to slowly follow a predetermined 

set of waypoints to return to a safety point if communications are lost.

James Tiblier does NOT operate its UASs near airports, national and state parks, and generally does not 

operate them near populated areas. The UAS operating software and GPS navigation systems do not 

allow any of the UAS vehicles to operate near airports or restricted fly zones. The failsafe software will 

disable the UAS vehicles from taking off and also limit the UAS systems from operating within specific 

GPS preset no-fly zones. We only operates its UASs in predetermined areas and only in compliance with 

well-regarded safety protocols such as those contained within the well-established and commonly 

known Motion Picture and Television Operations Manual. 

James Tiblier unmanned aircraft will not "create a hazard to users of the national airspace system or the 

public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight. James Tiblier UASs, combined with their 

operation in cordoned off and well-controlled areas, James Tiblier fleet falls within Congress's 

contemplated safety zone when it promulgated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system. Indeed, UASs have a demonstrable safety record and 

do not pose any threat to the general public or national security.

Reasons Why James Tiblier Exemption Will Not Adversely Affect Safety Or How The Exemption Will 

Provide a Level of Safety At Least Equal To Existing Rule: 

Quite the contrary, for the reasons stated, supra, permitting James Tiblier to log more flight time in FAA 

controlled airspace will allow the team to innovate and implement new and as of yet undiscovered 

safety protocols. In addition, James Tiblier submits the following representations of enhancements to 

current aerial motion picture capture techniques: 
• UASs weigh less than 55 pounds complete with feature length motion picture quality cameras like the 

Sony NEX V G 1 0; 

• UAS only operates below 400 feet; 

• UASs only operate for 8-ten minutes per flight; 

• lands its UASs when they reach 20% battery power; 

• Remote control pilots operate UASs by line of sight and with a spotter; 

• Remote control pilots have video backup should they somehow lose sight of the UAS; 

• UASs have GPS flight modes whereby they hover and then slowly land if communication with the 

remote control pilot is lost or battery power is below20%; 

• Actively analyses electronic flight data and other sources of information to constantly update and 

enhance safety protocols; 

• Only operates in secured areas that are strictly controlled, are away from airports and populated 

areas;

• Conducts extensive briefmgs prior to flight, during which safety carries primary importance;

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. James 

Tiblier can achieve an equivalent level of safety as achieved by current Regulations James Tiblier UASs 

do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote 

control piloting skills, though pilot vetting and training programs will. Further, the risks attendant to the 

operation of UASs is far less than the risk levels inherent in the commercial activities outlined in 14 

C.F.R. § 61, et seq. Thus, allowing UASs with a private pilot as the pilot in control will exceed current 

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

James Tiblier respectfully requests that the FAA grant its exemption request without delay. The FAA has 

the authority to issue the exemption sought by James Tiblier pursuant to the Federal Aviation Act, 85 

P.L. 726 (1958), as amended (the "Act").