Approved Technologies

2060 D Avenida De Los Arboles

Suite #285

Thousand Oaks, CA 91362-1361

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

December 17, 2015

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 

91.121; 91.151(a); 91.405(a); 91.407(a)(I); 91.409 (a)(I) and (2); 91.417(a) and (b). 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform 

Act") and 14 C.F.R. Part 11, Approved Technologies, an operator of Unmanned Aircraft 

Systems ("UASs") for data collection, and aerial photography for the motion picture and 

television industry, hereby applies for an exemption from the Federal Aviation Regulations

("FARs") to allow commercial operation of its UASs. 

On September 25, 2014, the FAA granted exemptions to six UAS operators, including 

Astraeus Aerial (the "Astraeus Exemption"). As set forth in Approved Technologies Flight 

Operations and Procedures Manual (the "FOPM") and Motion Picture Television Operations 

Manual (both submitted under separately under 14 CFR 11.35(b)), Approved Technologies 

will adhere to the terms of the Astraeus Exemption. 

Approved Technologies requested exemption would permit the operation of small, unmanned 

UAS under controlled and "sterile" conditions in motion picture and television airspace that 

is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) designed to 

provide greater safety in connection with aircraft operations in the film and television 

industry. As established by the exemptions already granted by the FAA, approval of 

Approved Technologies’ exemption would enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for 

the safe operation of such aircraft systems in the national airspace system". Section 333(c) of 

the Reform Act. 
u.s. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Approved Technologies

December 17, 2015 

2

The name and address of the applicant is: 

Approved Technologies

Attn: Tom Hallman; Ph: 818-385-5435 

Email: tomhallman@verizon.net

Address: 2060 D Avenida De Los Arboles

Suit #285

Thousand Oaks, CA 91362-1361 

UAS to be used: 

The aircraft to be used with this exemption are:

DJI S1000

DJI S900

DJI Inspire 1

DJI Inspire 2

DJI Phantom2

DJI Phantom 3

Freefly Systems Alta

PV-HL1

PV-HL2

PV-HL3

PV-14817

Shotover U1

Riegl VUX-1

3DR Solo

AT-Heavy Lift 1

AT-Heavy Lift 2

AT-Heavy Lift 3

Aerigon IAH 3

Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 14 C.F.R. 91.103 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151(a) 

14 CFR 91.405(a) 

14 CFR 407(a)(I) 

14 CFR 409(a)(2) 

14 CFR 417(a) and (b)

UASs operated by Approved Technologies weigh less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, 
u.s. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Approved Technologies

December 17, 2015 

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and can simultaneously move vertically and horizontally. Approved Technologies will only 

operate its UASs in line of sight and will operate only within the sterile area described in the 

FOPM. Such operations will insure that the UAS will "not create a hazard to users of the 

national airspace system or the public." 

Given the small size of Approved Technologies’ UASs and the restricted sterile environment 

within which they will operate, Approved Technologies’ UAS operations adhere to the 

Reform Act's safety requirements. Additionally, due to the size of the UASs and the limited 

areas in which they will operate, approval of this application presents no national security 

issues. Based on the substantial level of safety surrounding the proposed operations, and the 

significant public benefit (enhanced safety), reduction in environmental impacts (reduced 

emissions and noise), the grant of the requested exemption is in the public interest. 

Accordingly, Approved Technologies respectfully requests that the FAA grant the requested 

exemption without delay. 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Approved Technologies provide for at least an 

equivalent or higher level of safety because operations further enhance safety of movie and 

television filming using conventional aircraft. 

As set forth in the FOPM, the limitations and conditions include: 

• The UASs will weigh less than 55 pounds 

• Flights will be operated within line of sight of a pilot and observer. 

• Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute 

limit. 

• Flights will be operated at an altitude of no more than 400 feet above ground level 

("AGL"), and not more than 200 feet above an elevated platform from which filming 

is planned. 

• Minimum crew for each operation will consist of the UAS Pilot, and the Visual 

Observer.

• A UAS pilot will be an FAA licensed airman with at least a sport pilot's certificate. 

• A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than 

the UAS Pilot, who possesses the necessary PIC qualifications, is also present onset 

(i.e. the Aerial Coordinator), that person can also be designated as PIC. 

• The UAS will only operate within a confined "Sterile Area" as defined in the FOPM. 
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Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Approved Technologies

December 17, 2015 

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The FOPM requires the establishment of a "Security Perimeter" for the flight 

operations area. 

• A briefing will be conducted for planned UAS operations prior to each day's flight. 

All personnel performing duties within the boundaries of the safety perimeter are 

required to attend. 

• The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate Flight Standards District Office 

("FSDO"). 

• The operator will obtain consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation. This 

radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required under the FOPM. With the advanced permission of the 

FSDO, operations at closer range can be approved. 

• The operator will submit a written Plan of Activities to the FSDO a minimum of three 

days before the proposed shoot as required in the FOPM. 

• The Pilot and observer must be trained in UAS operations and have received current 

information on the particular UAS to be operated as required by the FOPM. 

• The Observer and pilot will at all times be able to communicate by voice. 

• Written and /or oral permission from the relevant property holders will be obtained. 

• All required permissions and permits will be obtained from territorial, state, county, 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

• If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and 

land. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the PIC operating the aircraft to have a 

private pilot's license rather than a commercial pilot's license to operate a small UAS. Unlike 

a conventional manned aircraft, a UAS is remotely controlled by a ground based operator. 

The operational area is controlled and restricted, and all flights are planned and coordinated 

in advance. The level of safety exceeds that provided by a single individual holding a 

commercial pilot's certificate operating a conventional aircraft. The risks associated with the 
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December 17, 2015 

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use of a UAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 that allowing UAS use by a private pilot such as the PIC actually 

exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is 

requested. However, an equivalent level of safety will be provided. The PIC will take all 

actions, including reviewing weather, flight battery requirements, landing and takeoff 

distances, and aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

provides, in pertinent part, that: 

"except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: ..... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure." 

Because Approved Technologies requests authority to operate at altitudes only up to 400 feet 

AGL, and not more than 200 feet above an elevated platform from which filming is planned, 

an exemption is needed to allow such operations. The UAS will never operate higher than 

400 feet AGL. It will, however, be operated in a restricted area within a security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS 

as well as the location where it is operated. No flight will be taken without the permission of

property owners or local officials. Because of the advance notice to the property owners and 

participants in the filming activity, all affected individuals will be informed of the planned 

flight operations. Compared to flight operations for manned aircraft and the lack of 

flammable fuel, any risk associated with the proposed UAS operations is far less than 

conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between a UAS and conventional aircraft. 
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Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Approved Technologies

December 17, 2015 

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14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set"...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As a UAS may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent 

level of safety will be achieved by the operator, pursuant to the FOPM and Safety Check list, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing, and, assuming normal cruising speed -(1) During the 

day, to fly after that for at least 30 minutes ...." 

The batteries powering the Approved Technologies UASs provides approximately 40 

minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, 

UAS flights will be limited to approximately 10 minutes in length. Given the limitations on 

the UAS's proposed flight area and its proposed operations within a predetermined location, a 

longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating 

the UASs in a tightly controlled area where only people, property owners, or official 

representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel 

does not engender the type of risk that §91.151(a) was intended to address. Approved 

Technologies believes that safety can be achieved by limiting flights to 30 minutes or 25% of

battery power, whichever occurs first. This restriction would be more than adequate to return 

the UAS to its pre-determined landing zone from anywhere in its limited operating area. 

Approved Technologies is not seeking an exemption for night-time UAS operations. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner shall "have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter...,"and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Glide Aerials operations. Maintenance will be accomplished 

by the operator. An equivalent level of safety will be achieved because the UASs are limited 

in size, will carry a small payload and operate only in restricted areas for limited periods of
u.s. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Approved Technologies

December 17, 2015 

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time. If mechanical issues arise, the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the UAS 

is in working order prior to flight, perform any required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the UAS 

and best suited to maintain it in an airworthy condition. 

Summary for Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Approved Technologies seeks an exemption from the following rules: 

14 C.F.R. §§ 61.1 13(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(l); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned 

vehicle (55 pounds or less) in motion picture and television operations. 

As established by the UAS exemptions already granted by the FAA, allowing commercial 

operations of UASs in the film industry will enhance safety by reducing risk. In conventional 

film operations, turbine aircraft operate at low altitudes and present the risks associated with 

aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such 

aircraft must also fly to and from the film location. In contrast, a UAS weighing fewer than 

55 pounds and powered by batteries eliminates virtually all of that risk given the small size 

and lack of combustible fuel. The UAS is carried, and not flown, to a film set. In this regard, 

the UAS carries no passengers or crew and, therefore, will not expose them to the risks 

associated with manned flights. 

The operation of UASs conducted in the strict conditions outlined in the FOPM will provide 

an equivalent level of safety supporting the grant of the exemption requested herein. The 

UASs operate at slow speeds, close to the ground, and in a sterile environment. As a result, 

they are far safer than conventional operations conducted with turbine helicopters carrying 

fuel and flying near the ground and people. 

Privacy 

All flights will occur over private or controlled access areas with the property owner's prior 

consent and knowledge. Filming will be only of people who have given their consent or 

otherwise have agreed to be in the area where filming will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 
u.s. Department of Transportation 

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December 17, 2015 

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visual line of sight and national security) provide more than adequate justification to grant 

Approved Technologies’ requested exemption, allowing for Approved Technologies’ UAS 

commercial operations for the motion picture and television industry pursuant to the FOPM 

included herewith. 

If you have any questions or need any additional information, please contact the undersigned 

at 818-385-5435 or at tomhallman@verizon.net 

Sincerely,

Tom Hallman

Approved Technologies