1 September 15, 2015

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

Re: Petition of Airhead Media LLC for an Exemption Request Pursuant to

Section 333 of the FAA Reform Act a nd Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, Subpart H; 61.113(a) & (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.4 17(a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Mode rnization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Airhead Media LLC does hereby apply for an exemption from the Federal Aviation Regulatio ns ("FAR's") identified below, to allow commercial use of small unmanned aerial syst ems ("sUAS") for the purpose of aerial photography and filmmaking under certain cond itions set forth in the Airhead Media LLC confidential Flight Operations Manual and identical conditions set forth in the FAA-issued "Exemption No. 11062", and relate d exemptions issued to operators for closed set filming.

Also, pursuant to 14 CFR § 11.87, we request that the FAA not publish this petition request in the Federal Register and not delay action based on the following:

1. This petition for exemption does not set pr ecedent. Previous identical exemption requests have been approved.

2. The requested relief is identical to ex emptions granted previously, specifically, Exemption(s) Nos. 11062 (Astraeus Aerial), 11066 (A erial MOB), 11065 (Helivideo), and others.

3. A delay in action on this petition woul d adversely affect pending requests for aerial filming operations and result in lo st opportunity and wages for participating crew, and a delay in the public benefit of granting this pe tition. In addition, a competitive advantage for unapproved commercial sUAS operators exists and continues to grow every day.

4. We are filing this exemption petition immediately following the finalized operations manual with respect to newly acquired sUAS.

Notwithstanding the request not to publish this petition request in the Federal Register, Airhead Media LLC has submitted supporti ng materials including the confidential "Flight Operations Manual" which are conf idential documents pursuant to 14 CFR § 11.35(b) and are not available to the public.2 Pursuant to 14 CFR § 11.87:

a) The name and address of the applicant:

Airhead Media LLC 2051 Hampstead Road Cleveland Heights, Ohio 44118

b) 14 C.F.R. - Regulations for wh ich exemption is requested:

1. Part 21, Subpart H 2. 61.113(a) and (b) 3. 91.119(c)

4. 91.121 5. 91.151(a) 6. 91.405(a) 7. 91.407(a)(1) 8. 91.409(a)(2) 9. 91.417(a) and (b)

These regulation exemption requests are identical to the exemptions determined as necessary by the FAA in previously a pproved exemption petitions as described

above.

c.) The extent of relief sought, a nd reason for seeking relief:

1. Part 21 Subpart H: Airworthiness Certificates

The FAA has determined that no exemption is required of this section if a finding

is made under the Reform Act that the sUAS selected provides an equivalent level of safety when compared to aircraft nor mally used for the same application. As the aircraft specified in this exemption request meet the size , weight, speed and

other characteristics of sUAS aircraft specified in pr eviously approved exemption requests as noted, no exemption is belie ved to be needed. If, however, an exemption is determined to be needed by the FAA after review of this petition, one is requested.

An equivalent or greater level of safe ty is obtained when sUAS physical and operating characteristics, safety system s, maintenance requirements and other operating procedures as set forth in the attached Confidential Flight Operations

Manual are adhered to.3 2. 61.113(a) and (b): Private Pilot Priv ileges and Limitations: Pilot in

Command.

Airhead Media LLC is seeking relief from this regulation as the requirement for a

Commercial Pilot License with a second class medical would be an unnecessary

burden on the operator with regard to obtai ning and certifying UA pilots.

The UAS will not carry a pilot or pass engers, and the proposed operations can achieve the equivalent level of safety by requiring the pilot to possess a private pilot's license only, with a valid third cl ass medical. This level of knowledge and skill combined with the proposed operati ng procedures described in the Flight Operations Manual (VLOS only, closed-set requirements, etc.) will more than 4727 regard to persons or property on the ground. The additional knowledge and

skill requirements for a Commercial Pilot's lic ense do not add any level of safety with respect to closed-set small UAS operations in the same manner they do

with full scale, passenger-carrying aircraft.

An equivalent or greater level of safety is achieved by requiring UA pilots to have

a minimum number of hour s logged, flight sequences , knowledge and experience testing, etc. as described in the Flight Operations Manual.

3. 91.119(c): Minimum Safe Altitudes.

Airhead Media LLC is seeking relief from this regulation as the primary purpose of the UAS operation is to provide 'low altitude' aerial cinematography and photography services.

This section prescribes that an aircraft may not be operate d closer than 500 feet to any person, vessel, vehicle or structure in uncongested areas. As sUAS aircraft are much smaller, lighter, and operate at mu ch slower speeds than full size aircraft, and do not carry explosive fuel, the potenti al for injury and damage to persons and property on the ground is significantly lower in the event of an uncontrolled descent. In addition, with respect to participating persons on the ground, a full safety briefing would be conducted desc ribing flight operatio ns, including any risk. This is similarly done with restrictions and guidelin es for full size aircraft in accordance with an approved Motion Picture and Television Operations Manual, the applicable sections of which are in cluded in the FCAP Flight Operations

Manual.

An equivalent or greater level of safety is obtained than when using full size aircraft in similarly approved filming ope rations as the potential for injury and damage is significantly reduced when appl ying size, weight and speed restrictions on the UA. Also, the UA has built in safety features such as autoland, ability to

control with loss of an engine, etc. that full size aircraft may not have.4 4. 91.121: Altimeter Settings

Airhead Media LLC is seeking relief from this regulation as the UA will not

have a barometric altimeter.

An equivalent or greater level of safety exists as although th e UA does not have a typical barometric altimeter onboard, it doe s report GPS AGL altitude to the PIC via radio telemetric feed. This is combined with the UA being operated within visual line of sight and below 400’ AGL, and the pilot requirements to verify AGL reading prior to liftoff (as containe d in the Flight Op erations Manual).

5. 91.151(a): Fuel Requirements for Flight in VFR Conditions

Airhead Media LLC is seeking relief from the fuel requirements of this FAR as current battery technology allows the UA to fly for a pproximately 15-30 minutes

in normal conditions. As 91.151(a) requires a 30-minute reserve AFTER reaching the point of intended landing, there is no practical flight possible under this regulation.

An equivalent or greater level of safety exists as the exact battery level remaining is transmitted to the pilot via radio telemetry, and given that the operating area for the UA is in close proximity to the p ilot (VLOS), an unsaf e condition where the UA is unable to return for landing du e to low battery condition is easily avoidable. Additionally, should a defective battery prematurely deplete, the UA is configured to autoland above the point at which the flight cont roller detects low voltage. And, as part of the Airhead Media LLC Operations Manual, it is a requirement that any flight be terminated if telemetry is lost. Otherwise, a flight

limit of 30 minutes or 25% batt ery remaining is prescribed.

6-9. 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Airhead Media LLC is seeking relief fr om the above stated FAR's as the UA

will not have an airworthiness certificat e. Therefore there is no requirement to perform an inspection in order to mainta in airworthiness as stated in Appendix

D to Part 43 for 100hr. and annual inspections.

An equivalent or greater level of safety exists as the Airhead Media LLC Flight Operations Manual does prescribe re gular maintenance and inspections, compliance with manufacturer's service bulle tins, test flights after maintenance, technician training, and so forth, in the sp irit of the scope and detail of Appendix D to Part 43. In addition, while mechanical failures are not out of the question, a crash resulting from a catastrophic failure has a very small amount of risk of injury when compared to a failure in a passenger carrying full size aircraft, for which this regulation was intended.5 d) Public Interest:

Airhead Media LLC believes that allo wing commercial use of small-unmanned

aircraft will enhance the safety of filming operations by reducing the risk

associated with low altitude full size aircraft operations. A manned, turbine powered helicopter opera ting in close proximity to production personnel and actors on the ground has a far gr eater risk of injury than a small, lightweight UA carrying no combustible fuel, especially when the UA is operating within the parameters of the FCAP F light Operations Manual.

Additionally, the safe integr ation of sUAS within th e national airspace is a growing concern amongst pilo ts, the FAA, and genera l public. This exemption would provide a safe stepping-stone to a more robust set of future sUAS rules.

e) Level of Safety:

As outlined in each of the FAR's above fo r which relief is sought (underlined).

f) Summary:

Airhead Media LLC seeks exemption from the following rules for the commercial operation of a small unmanne d aerial system in order to conduct filming and photography operations below an altitude of 400’ AGL and within a limited operating area: 14 C.F.R. Part 21, Subpart H; 61.113(a) & (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.4 17(a) & (b).

This exemption will enhance the level of safety currently able to be obtained using full sized manned helicopters for the same type of work.

g) Additional Information:

Additionally, the sUAS aircraft specified in the attached Flight Operations Manual are unmodified, commercially produced ai rcraft by the largest consumer sUAS manufacturer worldwide, and have the la rgest user base of any sUAS, with a proven safety record. Size, weight, speed limitations and other operating

restrictions are described in the atta ched Flight Operations Manual and are consistent with other previously appr oved Section 333 exemptions for filmmaking. For reference, the UA specified have a gro ss weight of less than 55lbs and fly at a speed of no more than 50kts, carry neither a pilot nor a passenger, carry no explosive materials or flamma ble liquid fuels, and operate exclusively within a

secured area as set out in the Flight Operations Manua l. In addition, integrated safety features ensure the safety of persons and property within and surrounding the limited operating area by employing auto matic ‘return to home and land’ in the

event of command and control fa ilure, and other safety feat ures as described in the Flight Operations Manual.