Alexander	Mandiola T:	(305)496

- 2654	alexmandiola@gmail.com April	1,	2015

U.	S.	Department	of	Transportation	Docket	Management	System 1200	New	Jersey	Ave.,	SE	Washington,	DC	20590

Re:	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).

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,	Alexander	Mandiola,	developer	and operator	of	Small	Unmanned	Aircraft Systems	(“sUASs”)	equipped	to	conduct aerial	photography	for	the	motion	picture	and	television	industry	for	scripted closed	set	filming,	hereby	applies	for	an	exemption	from	the	listed	Federal Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of its	sUASs,	so 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

333.1 As	described	more	fully	below,	the	requested	exemption	would	permit	the operation	of	small, unmanned	and	relatively	inexpensive	sUAS	under controlled	conditions	in	airspace	that	is	1)	limited	2)	predetermined	3) controlled	as	to	access	and	4)	would	provide	safety	enhancements	to	the already	safe	operations	in	the	film	and	television	industry	pre sently	using conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s) responsibilities	to	“...establish	requirements	for	the	safe	operation	of	such aircraft	syste ms	in	the	national	airspace	system.”	Section	333(c)	of	the	Reform

Act.

The	name	and	address	of	the	applicant	is:

Alexander	Mandiola Ph:(305)496

- 2654 Email:	Alexmandiola@gmail.com Address:	55	ocean	lane	drive	#4020	Key	biscayne,	FL	33149 1	The	conditions	p roposed	by	the	applicant	are	drawn	from	Order	8900.1	CHG 0,	Volume	3,	Chapter	8

- Issue	a	Certificate	of	Waiver	for	Motion	Picture	and Television	Filming.

Regulations	from	which	the	exemption	is	requested:

14	CFR	Part	21 14	C.F.R.	45.23(b)14	CFR	61.113	(a) &	(b)	14	C.F.R.	91.7	(a) 14	CFR	91.9	(b)	(2)

14	C.F.R.	91.103

14	C.F.R.	91.109

14	C.F.	R.	91.119

14	C.F.R.	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b)	14	CFR	91.405	(a) 14	CFR	407	(a)	(1) 14	CFR	409	(a)	(2) 14	CFR	417	(a)	&	(b) This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in passing	Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the Secretary	of	Transportation	to	consider	whether	certain	unmanned	aircraft systems	may	operate	safely	i n	the	national	airspace	system	(NAS)	before completion	of	the	rulemaking	required	under	Section	332	of	the	Reform	Act. In	making	this	determination,	the	Secretary	is	required	to	determine	which types	of	UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	th e	public	or	pose	a threat	to	national	security	in	light	of	the	following: •	The	UAS’s	size,	weight,	speed,	and	operational	capability; •	Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and •	Operation	of	the	UAS	within	visual	line of	sight	of	the	operator. Reform	Act	§	333	(a).	Lastly,	if	the	Secretary	determines	that	such	vehicles “may	operate	safely	in	the	national	airspace	system,	the	Secretary	shall establish	requirements	for	the	safe	2	operation	of	such	aircraft	in	the	national airspace	system.”	Id.	§333(c)	(emphasis	added)	. The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue exemptions.	This	statutory	authority	by	its	terms	includes	exempting	civil aircraft,	as	the	term	is	defined	under	§40101	of	the	Act, that	includes	sUASs, from	the	requirement	that	all	civil	aircraft	must	have	a	current	airworthiness

certificate. 2	Applicant	interprets	this	provision	to	place	the	duty	on	the	Administrator	to not	only	process	applications	for	exemptions	under	section	333, but	for	the Administrator	to	craft	conditions	for	the	safe	operation	of	the	UAS,	if	it	should be	determined	that	the	conditions	set	forth	herein	do	not	fulfill	the	statutory requirements	for	approval.

The	Administrator	may	grant	an	exemption	from	a	re quirement	of	a regulation	prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any

sections	44702

- 44716	of	this	title	if	the	Administrator	finds	the	exemption	in the	public	interest.	49	U.S.C.	§44701(f)	See	also	49	USC	§44711(a);	49	USC §44704;	14	CFR §91.203	(a)	(1). Alexander	Mandiola	sUASs	are	rotorcraft,	weighting	55	or	fewer	lbs.	including payload.	They	operate,	under	normal	conditions	at	a	speed	of	no	more	than	50 knots	and	have	the	capability	to	hover,	and	move	in	the	vertical	and horizontal	pla ne	simultaneously.	They	will	operate	only	in	line	of	sight	andwill	operate	only	within	the	sterile	area	described	in	the	Confidential	Motion Picture	and	Television	Operations	Manual,	attached	as	Exhibit	1	(hereinafter “the	Manual”)3.	Such	operations	will insure	that	the	sUAS	will	“not	create	a hazard	to	users	of	the	national	airspace	system	or	the	public.”4

Given	the	small	size	of	the	sUASs	involved	and	the	restricted	sterile environment	within	which	they	will	operate,	the	applicant	falls	squarely

within	t hat	zone	of	safety	(an	equivalent	level	of	safety)	in	which	Congress envisioned	that	the	FAA	must,	by	exemption,	allow	commercial	operations	of UASs	to	commence	immediately.	Also	due	to	the	size	of	the	UASs	and	the

restricted	areas	in	which	the	relevant	sU ASs	will	operate,	approval	of	the application	presents	no	national	security	issue.	Given	the	clear	direction	in Section	333	of	the	Reform	Act,	the	authority	contained	in	the	Federal	Aviation Act,	as	amended;	the	strong	equivalent	level	of	safety	surroundin g	the proposed	operations,	and	the	significant	public	benefit,	including	enhanced safety,	reduction	in	environmental	impacts,	including	reduced	emissions associated	with	allowing	UASs	for	movie	and	television	operations,	the	grant of	the	requested	exemptio ns	is	in	the	public	interest.	Accordingly,	the applicant	respectfully	requests	that	the	FAA	grant	the	requested	exemption without	delay. AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY The	applicant	proposes	that	the	exemption	requested	herein	apply	to	civil

aircr aft	that	have	the	characteristics	and	that	operate	with	the	limitations listed	herein.	These	limitations	provide	for	at	least	an	equivalent	or	even higher	level	of	safety	to	operations	under	the	current	regulatory	structure because	the	proposed	operations represent	a	safety	enhancement	to	the already	safe	movie	and	television	filming	operations	conducted	with

conventional	aircraft. These	limitations	and	conditions	to	which	Alexander	Mandiola	agrees	to	be bound	when	conducting	commercial	operations	under	an FAA	issued exemption	include:

3	The	Motion	Picture	Association	of	America	has	reviewed	this	manual	and has	found	it	to	be	acceptable	for	sUAS	filming	operations	for	the	television	and movie	industry.	Applicant	submits	this	manual	as	a	Confidential	document under	14	CFR	11.35	(b)	as	the	entire	manual	contains	proprietary	information that	the	applicant	has	not	and	will	not	share	with	others.	The	manual	contains operating	conditions	and	procedures	that	are	not	available	to	the	public	and are	protected	from	rel ease	under	the	Freedom	of	Information	Act	5	USC	552
et.seq. 4	Reform	Act	Section	333	(b).

1.	The	sUAS	will	weigh	less	than	55	lbs. 2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer. 3.	Maximum	total	flight	time	for	eac h	operational	flight	will	be	30	minutes. Flights	will	be terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the	30

minutelimit. 4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not

more	than

200	feet	above	an	ele vated	platform	from	which	filming	is	planned. 5.	Minimum	crew	for	each	operation	will	consist	of	the	sUAS	Pilot,	the	Visual Observer, and	the	Camera	Operator. 6.	sUAS	pilot	will	be	an	FAA	licensed	airman	with	at	least	a	private	pilot’s

certificate	and

third	class	medical.	The	observer	will	hold	at	least	a	third	class	medical. 7.	sUAS	Pilot	will	be	Pilot	in	Command	(PIC).	If	a	pilot	certificate	holder	other

than	the sUAS	Pilot,	who	possess	the	necessary	PIC	qualifications,	is	also	present	on	set (i.e.

th e	Aerial	Coordinator),	that	person	can	also	be	designated	as	PIC. 8.	The	UAS	will	only	operate	within	a	confined	“Sterile	Area”	as	defined	in	the Manual.	Section	H,	I	and	J	of	the	Manual	requires	the	establishment	of	a “Security	Perimeter” for	the	flight	o perations	area. 9.	A	briefing	will	be	conducted	in	regard	to	the	planned	sUAS	operations	prior

to	each day’s	production	activities.	It	will	be	mandatory	that	all	personnel	who	will	be performing	duties	within	the	boundaries	of	the	safety	perimeter	be	prese nt for	this	briefing. 10.	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. 11.	The	operator	will	obtain	the	consent	of	all	persons	involved in	the	filming and	ensure	that	only	consenting	persons	will	be	allowed	within	100	feet	of	the flight	operation,	and	this	radius	may	be	reduced	to	30	feet	based	upon	an equivalent	level	of	safety	determination,	as	required	by	Section	K	of	the

Manual.	With	t he	advanced	permission	of	the	relevant	FSDO,	operations	at closer	range	can	be	approved. 12.	The	operator	will	submit	a	written	Plan	of	Activities	to	the	FSDO	three days	before	the	proposed	shoot	as	required	in	Section	K	of	the	Manual.

13.	Pilot	and	observ er	will	have	been	trained	in	operation	of	UAS	generally and	received	up

- to

- date	information	on	the	particular	UAS	to	be	operated	as required	Sections	M	and	N	of	the	Manual. 14.	Observer	and	pilot	will	at	all	times	be	able	to	communicate	by	voice and/or	tex t. 15.	Written	and/or	oral	permission	from	the	relevant	property	holders	will	be

obtained. 16.	All	required	permissions	and	permits	will	be	obtained	from	territorial,
state,	county	or city	jurisdictions,	including	local	law	enforcement,	fire,	or	other	appr opriate governmental	agencies.17.	If	the	sUAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have capability	to	return	to	a	pre

- determined	location	within	the	Security

Perimeter	and

land. 18.	The	sUAS	will	have	the	capability	to	abort	a	flight in	case	of	unpredicted

obstacles	or emergencies.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a) (1) Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural requirements	for	the	issuance	of	airworthiness certificates	as	required	by	FAR §91.203	(a)	(1).	Given	the	size	and	limited	operating	area	associated	with	the aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H meets	the	requirements	of	an	equivalent	level	of	safety	under	Part 11	and Section	333	of	the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701	(f)) and	Section	333	of	the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft from	the	requirement	for	an	airworthiness	certificate,	upon	consideration	of the	size,	weight, speed,	operational	capability,	and	proximity	to	airports	and populated	areas	of	the	particular	UAS.	In	all	cases,	an	analysis	of	these	criteria demonstrates	that	the	UAS	operated	without	an	airworthiness	certificate,	in

the	restricted	environment	and	under the	conditions	proposed	will	be	at	least as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	rotorcraft) operating	with	an	airworthiness	certificate	without	the	restrictions	and conditions	proposed. The	sUAS	to	be	operated	hereunder	is	less	tha n	55	lbs.	fully	loaded,	carries neither	a	pilot	nor	passenger,	carries	no	explosive	materials	or	flammable liquid	fuels,	and	operates	exclusively	within	a	secured	area	as	set	out	in	the Manual.	Unlike	other	civil	aircraft,	operations	under	this	exemption	w ill	be tightly	controlled	and	monitored	by	both	the	operator,	pursuant	to	the Manual’s	requirements,	and	under	the	requirements	and	in	compliance	with local	public	safety	requirements,	to	provide	security	for	the	area	of	operation

as	is	now	done	with	conve ntional	filming.	The	FAA	will	have	advance	notice	of all	operations.	These	safety	enhancements,	which	already	apply	to	civil aircraft	operated	in	connection	with	motion	picture	and	television production,	provide	a	greater	degree	of	safety	to	the	public	and property owners	than	conventional	operations	conducted	with	airworthiness certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	application	of

these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	national security	posed	by	the	UA S,	due	to	its	size,	speed	of	operation,	location	of operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	inability to	carry	a	substantial	external	load. 14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft The	regulation	requires: When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration number	is	displayed	on	limited,	restricted	or	light

- sport	category	aircraft	orexperimental	or	provisionally	certificated	aircraft,	the	operator	must	also display	on	that	aircraft	ne ar	each	entrance	to	the	cabin,	cockpit,	or	pilot station,	in	letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or	"provisional," as	applicable. Even	though	the	UAS	will	have	no	air worthiness	certificate,	an	exemption	may be	needed	as	the	UAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot

station	on	which	the	word

“Experimental”	can	be	placed.	Given	the	size	of	the	sUAV,	two

- inch	lettering will	be	impossible.	The	word	“Experim ental”	will	be	placed	on	the	fuselage	in compliance	with	§45.29	(f). The	equivalent	level	of	safety	will	be	provided	by	having	the	sUAV	marked	on its	fuselage	as	required	by	§45.29	(f)	where	the	pilot,	observer	and	others working	with	the	sUAV	will	see	the identification	of	the	UAS	as	“Experimental.” The	FAA	has	issued	the	following	exemptions	to	this	regulation	to	Exemptions Nos.	10700,	8738,	10167	and	10167A. 14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in

Command.

Section s	61.113	(a)	&	(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	this	small	UAS.	Unlike	a	conventional aircraft	that	carries	the	pilot	and	passengers,	the	sUAS	is	remotely	controlled with	no	living	thing	on	board.	The	area	of	operatio n	is	controlled	and restricted,	and	all	flights	are	planned	and	coordinated	in	advance	as	set	forth in	the	Manual.	The	level	of	safety	provided	by	the	requirements	included	in the	Manual	exceeds	that	provided	by	a	single	individual	holding	a	commercial pil ot’s	certificate	operating	a	conventional	aircraft.	The	risks	associated	with the	operation	of	the	sUAS	are	so	diminished	from	the	level	of	risk	associated with	commercial	operations	contemplated	by	Part	61	when	drafted,	that allowing	operations	of	the	sUA S	as	requested	with	a	private	pilot	as	the	PIC exceeds	the	present	level	of	safety	achieved	by	14	C.F.R.	§61.113	(a)	&	(b). 14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness. The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is

i n	airworthy	condition.	As	there	will	be	no	airworthiness	certificate	issued	for the	aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	and	the requirements	contain ed	in	the	Manual	for	maintenance	and	use	of	safety check	lists	prior	to	each	flight,	as	set	forth	in	Sections	J,	L	and	Q,	an	equivalent level	of	safety	will	be	provided. 14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft. Section	91.9	( b)	(2)	provides: No	person	may	operate	a	U.S.

- registered	civil	aircraft	...(2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5 of	this	chapter,	unless	there	is	available	in	the	aircraft	a	current	approved airplane	or	Rotorcraft Flight	Manual,	approved	manual	material,	markings, and	placards,	or	any	combination	thereof.

The	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft. The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual at	the	ground	control	point	where	the	pilot	flying	the	sUAS	will	have

immediate	access	to	it.	The	FA A	has	issued	the	following	exemptions	to	this regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B, 10167,	10167A,	10602,	32827,	and	10700. 14	C.F.R.	§	91.103:	Preflight	action This	regulation	requires	each	pilot	in	command	to	take	certain actions	before flight	to	insure	the	safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals will	not	be	provided	for	the	aircraft	an	exemption	will	be	needed.	An equivalent	level	of	safety	will	be	provided	as	set	forth	in	Sections	J	and	K	of	the

Manua l.	The	PIC	will	take	all	actions	including	reviewing	weather,	flight battery	requirements,	landing	and	takeoff	distances	and	aircraft	performance data	before	initiation	of	flight. 14	C.F.R.	§91.109:	Flight	instruction: Section	91.103	provides	that	no	perso n	may	operate	a	civil	aircraft	(except	a manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that aircraft	has	fully	functioning	dual	controls. sUASs	and	remotely	piloted	aircraft,	by	their	design	do	not	have	fully

functional	dual	control s.	Flight	control	is	accomplished	through	the	use	of	a

control	box	that	communicates	with	the	aircraft	via	radio	communications. The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional

dual	controls	for	a	number	of	aircraft	and	for	fli ght	instruction	in experimental	aircraft.	See	Exemption	Nos.5778K	&	9862A.	The	equivalent level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be carried	in	the	aircraft	and	by	the	size	and	speed	of	the	aircraft. 14	C.F.R.	§91.119: Minimum	safe	altitudes Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section 91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums prescribed,	provided	the	person	operating	the	helicopter	complies	with	any

rou te	or	altitudes	prescribed	for	helicopters	by	the	FAA.	As	this	exemption	is for	a	sUAS	that	is	a	helicopter	and	the	exemption	requests	authority	to	operate at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	platform from	which	filming	is	pl anned,	an	exemption	may	be	needed	to	allow	such operations.	As	set	forth	herein,	except	for	the	limited	conditions	stated	in	the Manual,	the	UAS	will	never	operate	at	higher	than	400	AGL.	It	will	however	be operated	in	a	restricted	area	with	security	perim eter,	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,	speed	of the	UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be taken without	the	permission	of	the	property	owner	or	local	officials.	Because	of	the advance	notice	to	the	property	owner	and	participants	in	the	filming	activity, all	affected	individuals	will	be	aware	of	the	planned	flight	operations	as	set

forth	in	Se ction	K	of	the	Manual.	Compared	to	flight	operations	with	aircraft	or rotorcraft	weighting	far	more	than	the	maximum	55lbs.	proposed	herein	and the	lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less than	those	presently	presented with	conventional	aircraft	operating	at	or below	500	AGL	in	the	movie	industry.	In	addition,	the	low

- altitude	operations of	the	sUAS	will	ensure	separation	between	these	small

- UAS	operations	and the	operations	of	conventional	aircraft	that	must	comply	wi th	Section	91.119. 14	C.F.R.	§91.121	Altimeter	Settings This	regulation	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	altime ter	setting	available	before departure.”	As	the	sUAS	may	not	have	a	barometric	altimeter,	but	instead	a GPS	altitude	read	out,	an	exemption	may	be	needed.	An	equivalent	level	of safety	will	be	achieved	by	the	operator,	pursuant	to	the	Manual	and	Safety

Che ck	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	cruis ing	speed

– (1)	During	the	day,	to	fly	after	that	for at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.” The	battery	powering	the	sUAS	provides	approximately	40	minutes	of powered	flight.	To	meet	the	30	minute	reserve	require ment	in	14	CFR §91.151,	sUAS	flights	would	be	limited	to	approximately	10	minutes	in	length. Given	the	limitations	on	the	UAS’s	proposed	flight	area	and	the	location	of	its proposed	operations	within	a	predetermined	area,	a	longer	time	frame	for flight	in daylight	or	night	VFR	conditions	is	reasonable. Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin Corporation	to	operate	without	compliance	with	FAR	91.151 (a)).	Operating the	small	UAS,	in	a	tightly	controlled	area	where	only	people	and	property owners	or	official	representatives	who	have	signed	waivers	will	be	allowed, with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the	type	of	risks

that	Secti on	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of the	small	UAS.	Additionally,	limiting	sUAS	flights	to	10	minutes	would	greatly reduce	the	utility	for	which	the	exemption	will	be	granted. Applicant	believes	that	an	equivalent	level	of	saf ety	can	be	achieved	by limiting	flights	to	30	minutes	or	25%	of	battery	power	whichever	happens first.	This	restriction	would	be	more	than	adequate	to	return	the	sUAS	to	its planned	landing	zone	from	anywhere	in	its	limited	operating	area.Similar	exemptio ns	have	been	granted	to	other	operations,	including Exemptions	2689F,	5745,	10673,	and	10808. 14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and Registration The	regulation	provides	in	pertinent	part: (a)	Except	as	provided	in	§	91.71 5,	no	person	may	operate	a	civil	aircraft unless	it	has	within	it	the	following: (1)	An	appropriate	and	current	airworthiness	certificate.	.	.	. (b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate required	by	paragraph	(a)	of	th is	section	or	a	special	flight	authorization issued	under	§91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is legible	to	passengers	or	crew. The	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an onboard	pilot.	As	such, there	is	no	ability	or	place	to	carry	certification	and registration	documents	or	to	display	them	on	the	sUAS. An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at the	ground	control	point	where	the	pilot	flying	the	sUAS	will	have	i mmediate access	to	them,	to	the	extent	they	are	applicable	to	the	sUAS.	The	FAA	has issued	numerous	exemptions	to	this	regulation.	A	representative	sample	of other	exceptions	includes	Exemption	Nos.	9565,	9665,	9789,	9789A,	9797, 9797A,	9816A,	and	10700.

1 4	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	inspec tions,	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	section	and	Part	43	apply	o nly	to	aircraft	with	an airworthiness	certificate,	these	sections	will	not	apply	to	the	applicant. Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight manual	and	operating	handbook	as	referenced	in	the	Manual.(See	Sections	L and	Q)	An	e quivalent	level	of	safety	will	be	achieved	because	these	small	UASs are	very	limited	in	size	and	will	carry	a	small	payload	and	operate	only	in restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise	the	UAS can	land	immediately	and	will	b e	operating	from	no	higher	than	400	feet	AGL. As	provided	in	the	Manual,	the	operator	will	ensure	that	the	UAS	is	in	working order	prior	to	initiating	flight,	perform	required	maintenance,	and	keep	a	log of	any	maintenance	performed.	Moreover,	the	operator is	the	person	most

familiar	with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an airworthy	condition	to	provide	the	equivalent	level	of	safety.

********* Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for publication	in	the	F ederal	Register,	should	it	be	determined	that	publication	is

needed: Applicant	seeks	an	exemption	from	the	following	rules:14	C.F.R.	§21,	subpart	H;	14	C.F.R	45.23(b);14	C.F.R.	§§	61.113(	a)	&	(b);91.7 (a);	91.9	(b)	(2);91.103(b);91.109;	91.119;	91.121;	9 1.151(a);91.203(a)	and (b);	91.405	(a);	91.407	(a)	(1);	91.409	(a)	(2);	91.409	(a)	(2)	and	91.417	(a)	& (b)	to	operate	commercially	a	small	unmanned	vehicle	(55lbs	or	less)	in motion	picture	and	television	operations. Approval	of	exemptions	allowing	commer cial	operations	of	sUASs	in	the	film industry	will	enhance	safety	by	reducing	risk.	Conventional	film	operations, using	jet	or	piston	power	aircraft,	operate	at	extremely	low	altitudes	just	feet from	the	subject	being	filmed	and	in	extreme	proximity	to	peo ple	and structures;	and	present	the	risks	associated	with	vehicles	that	weigh	in	the neighborhood	of	4,000lbs.,	carrying	large	amounts	of	jet	A	or	other	fuel	(140 gallons	for	jet	helicopters	shown	below).	Such	aircraft	must	fly	to	and	from	the

film	locatio n.	In	contrast,	a	sUAS	weighing	fewer	than	55	lbs.	and	powered	by batteries	eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack

of	combustible	fuel	carried	on	board.	The	sUAS	is	carried	to	the	film	set	and not	flown.	The	sUAS	will	carry	n o	passengers	or	crew	and,	therefore,	will	not expose	them	to	the	risks	associated	with	manned	aircraft	flights. The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	conducted	in	the strict	conditions	outlined	above,	will	provide	an	equivalent	level	of safety supporting	the	grant	of	the	exemptions	requested	herein,	including	exempting the	applicant	from	the	requirements	of	Part	21	and	allowing	commercial operations.	These	lightweight	aircraft	operate	at	slow	speeds,	close	to	the ground,	and	in	a	sterile environment	and,	as	a	result,	are	far	safer	than conventional	operations	conducted	with	turbine	helicopters	operating	in close	proximity	to	the	ground	and	people. Privacy All	flights	will	occur	over	private	or	controlled	access	property	with	the
property owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	who have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area where	filming	will	take	place. Set	forth	below	are	pictures	of	aerial	filming	conducted	in	both	day	and	night environment,	as	flown	today	in	highly	populated	and/or	urban	areas,	with turbine	powered	helicopters.	The	grant	of	this	exemption	request	will	provide improved	safety	in	both	day	and	night	operations. Satisfaction	of	the	criteria	provided	in	Section	333	o f	the	Reform	Act	of	2012

-- size,	weight,	speed,	operating	capabilities,	proximity	to	airports	and populated	areas	and	operation	within	visual	line	of	sight	and	national	security

– provide	more	than	adequate	justification	for	the	grant	of	the	requested

exemp tions	allowing	commercial	operation	of	applicant’s	UAS	in	the	motion picture	and	television	industry	pursuant	to	the	Manual	appended	hereto.

Sincerely,

Alexander	Mandiola