UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

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STRATO AERIAL PRODUCTIONS , Petitioner. Docket No. FAA

- 201 5

- 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 52 0 Annapolis, MD 21401 Phone: 410

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- 3000 Fax: 410

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- 0098 tim.adelman@leclairryan.com Submitted on November 2 3 , 201 52

ORIGINAL PETITION SUBMISSION AND AGENCY RESPONSE On July 7, 2015, undersigned counsel submi tted 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 g rant ing 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 Doc k et 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.3

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 Serv ice 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 o f 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, Petiti oner 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 UA S 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 UAS4

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 abo ve, 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 servic es 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 c onduct UAS operations over controlled

- access property. Respectfully Submitted,

Tim B. Adelman Leclair Ryan, P.C. COUNSEL FOR STRATO AERIAL PRODUCTIONS