September 25, 2014
Thomas Webb Chris Walsh ELEVATED PERSPECTIVE MEDIA 36 POST ROAD WARWICK RHODE ISLAND 02888 401-261-5117
United States Department ofTransportation Docket Management System 1200 NewJerseyAve SE West Building Ground Floor Room W12-140 Washington, DC 20590



### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear FAA, - l;

\_.

We are writing regarding the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the procedures contained in:

14C.F.R. 11
Elevated Perspective Media, an operator ofsmall-unmanned aircraft, is requesting to be exempted frorn the Federal Aviation Regulations listed below. So that ELEVATED PERSPECTIVE MEDIA may operate it's lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"). As long as Elevated Perspective Media's operations are conducted within the established bythe 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-lssue aCertificate ofWaiverfor Motion Picture and Television Filming.

Thomas Webb, Chris Walsh and Judson Bell and Their company: ELEVATED PERSPECTIVE MEDIA is an experienced company and the combined years of knowledge in the film industryexceeds 40years. ELEVATED PERSPECTIVE MEDIA and its members have been working with special effects on set forgreat movies like Fast and the Furious, the Green Lantern and Shutter Island. More importantlywe have over 100 hours offlight training in the physical world and over 200 hours on asimulator.
ELEVATED PERSPECTIVE MEDIA has been involved in the technical development ofUAS"s to provide high qualityaerial cinematography with small, unmanned aircraft. ELEVATED PERSPECTIVE MEDIA has been working with multirotors for over 5years, developing technical and practical expertise. ELEVATED PERSPECTIVE MEDIA is also currently developing a curricula forfuture (withthe blessing ofthe FAA) a certification process for uas pilots.
Elevated Perspective Media's request tofilm and produce high qualityvideo exclusively forfilm and production companies would allow itto be thevanguard ofsafety and correct flight procedures. Elevated Perspective Media already has adetailed safety plan in place with numerous fail-safes to insure safetyto all involved. Above all else is our concern forsafety. Allowing Elevated Perspective Media to operate is productive to not only our benefit butalso to numerous other industries, as we are adding to aburgeoning industryand creatingjobs in an otherwise down economy.
Elevated Perspective Media respectfully requests the grant ofan exemption allowing itto operate lightweight, remote controlled UAS'Ss.

### The Specific Sections ofTitle 14ofthe Code of Federal Regulations, Elevated Perspective Media Requests Exemption are: 14 CFR 21 14 CFR 45.23(b) 14 CFR 61.113 (a) 

### & (b) 14CFR 61.3 (a) (1) (i) --------------(as none of us has apilot's license, this, Ibelieve this is the rule thatwould exempt us from that requirement, ourpic (pilot in command, eitherChris Walsh orThomas Webb has over 5years experience flying UAS's and hundreds of hours on a simulator.)
91.7 (a) 91.9 (b) (2) 91.103(b) 91.1OS 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).

Elevated Perspective Media's reasons for relief are simple: Without the exemption our business is notviable, we will not operate our business of cinematic filming on closed sets without the FAA's blessing. ELEVATED PERSPECTIVE MEDIA realizes that reasons for relief are more complex than stated directly above, below are reasons whywe would like tofly and why it makes America abetterplace. We seek relief to be the leading voice ofsafetyand responsible practices when itcomes to filming with UAS's.
112 P.L. 95 

### §§ 331-334
Elevated Perspective Media is seeking relief from any currently applicable FARs to prevent us fromworking on aclosed set cinematic production. The Reform Act in Section 332 provides forsuch integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Elevated Perspective Media lightweight UASs meetthe definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of Elevated Perspective Media lightweight UAS'S are expressly contemplated bythe Reform Act. Elevated Perspective Media would like to operate its lightweight UAS'S prior to the time period bywhich the Reform Act requires the FAAto promulgate rules governing such craft.
The Reform Act guides the Secretary in determining the types of UAS'S that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS; Whetherthe UAS will be operated near airports orpopulated areas; and, Whetherthe UAS will be operated by line of sight.

Each ofthese items urges in favor of an exemption for Elevated Perspective Media: a) Elevated Perspective Media UAS'S has: -an Aervonics SkyJib frame with a DJI A2 flight system -Tiger Motors, considered the best in the industry -A Futaba transmitter, also considered an industry leader -Eight counter-rotating propellers forextreme balance, control and stability. -Weigh less than 55 pounds, including cinematic or otherequipment. -Hover in place and operate at less than a50-knot maximum speed. -Line ofsight ofthe remote control pilot. -At all times there is aspotter, pilot and acameraman.
b) Elevated Perspective Media uses batterypower: -Uses battery power and not carbon fuel. -Never does the batterygo below 25% capacitywith safeguards not only on the batteryitself butalso on the safety system. -GPS system is in place to control the UAS ifany loss of connection occursc) Elevated Perspective Media follows AMA guidelines -does notoperate its UASs near airports and generally does not operate them nearpopulated areas. -The UAS operating software and GPS navigation systems do not allow any ofthe Elevated Perspective Media UAS vehicles to operate nearairports orrestrictedfly zones. -The failsafe software will disable the UASvehicles from taking offand also limitthe UAS systems from operating within specific GPS preset no-fly zones. To date, Elevated Perspective Media has only operated itsfleet as prescribed by the AMA. Elevated Perspective Media onlyoperates its UASs in predetermined areas and only in compliance with well regarded safetyprotocols such as those contained within the well established and commonly known Motion Picture and Television Operations Manual.
Elevated Perspective Media operation ofitsfleet ofsmall-unmanned aircraftwill not "create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 

### § 333 (b). Given the small size and weight of Elevated Perspective Media UASs, combined with theiroperation in cordoned offand well-controlled areas, Elevated Perspective Media fleet falls within Congress's contemplated safety zone when it authored the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Indeed, Elevated Perspective Media UASs have ademonstrable safety record and do not pose any threatto the general public or national security.

The FAA has the authorityto issue the exemption to Elevated Perspective Media pursuant to:
The Federal Aviation Act, 85 P.L. 726 (1958)
As apublic benefit Elevated Perspective Media will advance: -research into future safety guidelines forthe use ofUAS -Reducing dangers by limiting the use of larger helicopters, -Reducing carbon emissions. -Advancement ofart. -Advancement ofscience through advanced data collection.
Elevated Perspective Media Exemption will not alterorchange safetyto the public and iffact, advance it, here are the reasons why: -Longerflight times equal more practice. -Elevated Perspective Media UASs weigh less than 55 pounds -Elevated Perspective Media only operates its UASs below 400feet -Elevated Perspective Media UASs only operate for 5-16 minutes perflight -Elevated Perspective Media lands its UASs when they reach 25% battery power -Elevated Perspective Media remote control pilots operate by line ofsight. -Elevated Perspective Media staffs each flight with apilot, cameraman and aspotter. -Elevated Perspective Media UAS'S have gps modes to control UAS when communication is lost. -Elevated Perspective Media only operates in secured areas thatare strictlycontrolled. -Elevated Perspective Media uses safety meetings before and aftereach flight to ensure protocols are used. -Elevated Perspective Media always obtains all necessary permissions and permits priorto operation.
The bottom line is safety is our numberone priorityand adhering to astrict protocol is ofthe utmost importance. Granting this exemption would allow us to be the vanguard forsafety and correct protocol for uas. Elevated Perspective Media respectfully requests thatthe FAA grant its exemption request. The FAA has the authority to issue the exemption to Ele ated Perspective Media pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").
SincereI

Treasurer