UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

___________________________________________________

STRATO AERIAL PRODUCTIONS,

 Petitioner.

Docket No. FAA-2015-3865

SUPPLEMENT TO PETITION OF STRATO AERIAL PRODUCTIONS 

FOR AN EXEMPTION FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS: PUBLIC INTEREST 

STATEMENT

Tim B. Adelman

Leclair Ryan, P.C.

180 Admiral Cochrane Drive, Suite 520

Annapolis, MD 21401

Phone: 410-224-3000

Fax: 410-224-0098

tim.adelman@leclairryan.com

Submitted on November 23, 2015
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ORIGINAL PETITION SUBMISSION AND AGENCY RESPONSE

On July 7, 2015, undersigned counsel submitted PETITION OF STRATO 

AERIAL PRODUCTIONS FOR AN EXEMPTION FROM TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS TO PERMIT UNMANNED AIRCRAFT 

SYSTEMS (UAS) OPERATIONS on behalf of Strato Aerial Productions (Strato). In 

a letter dated November 13, 2015, the Federal Aviation Administration (Agency) 

responded to the petition requesting further information from Strato pertaining to 

how granting its Petition would satisfy 14 C.F.R. § 11.81(d)—“the reasons why 

granting the request would be in the public interest; that is, how it would benefit 

the public as a whole.” This Supplement is Strato’s response to this specific 

inquiry and a renewal of its petition to be granted an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 

2012. 

SUPPLEMENTAL REASONS WHY AN EXEMPTION WOULD 

FURTHER THE PUBLIC INTEREST

With the Agency’s granting of Strato’s exemption petition, Strato will be 

able to safely conduct its UAS operations for aerial photography, videography and 

closed-set filming. Similar exemption petitions were granted in Grants of 

Exemption Nos. 11062 Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 

to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC 

(see Docket No. FAA-2014-0382), 11213 to Aeryon Labs, Inc. (see Docket No. 
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FAA-2014-0642), 12645 to Allied Drones (see Docket No. FAA-2014-0804) and 

RC Aerial Platforms, LLC (see Docket No. FAA-2015-3172). As John S. Duncan, 

Director, Flight Standards Service for the Agency stated in Exemption No. 13566, 

“the enhanced safety achieved using an unmanned aircraft (UA) with the 

specifications described by the petitioner [in Exemption No. 13566] and carrying 

no passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, gives the FAA good 

cause to find that the UAS operation enabled by this exemption is in the public 

interest.” 

Adopting Director Duncan’s public interest rationale, Petitioner here asserts 

that granting an exemption for its fleet of five UA, flown within access-controlled, 

secure environments in accordance with the Conditions and Limitations submitted 

to the Agency as Exhibit A to Petitioner’s original Petition will further the public 

interest in the same way as Exemption No. 13566 and the other exemptions cited 

above. Further, granting Petitioner’s exemption is in the public interest because its 

UAs are far less invasive to the communities near which it will conduct its UAS 

operations. Alternative methods of aerial filming such as use of a helicopter 

represent significant noise, safety and environmental impacts on neighborhoods as 

well as a higher airspace impact that will be avoided through Petitioner’s use of its 

UAS. Finally, as was stated in Exemption Petition No. 11109, Petitioner’s UAS 
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will reduce the environmental impact by dramatically decreasing the energy used 

for aerial imaging from a manned aerial vehicle powered by fossil fuels. 

CONCLUSION

As set forth above, Strato seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012. The 

exemption will permit safe operation of the Strato UAS fleet for the special 

purpose of providing aerial cinematography services to production companies 

working in the United States. By granting this petition, the FAA Administrator 

satisfies the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the public interest by allowing Strato to conduct UAS 

operations over controlled-access property. 

Respectfully Submitted,

Tim B. Adelman

Leclair Ryan, P.C.

COUNSEL FOR STRATO AERIAL 

PRODUCTIONS