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Center Stage Videos

Attn: Matthew T Wise

7517 Keith Lane Sachse, TX 75048

July 7, 2015

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

Re: Exemption Request Pursuant to Section 333 of th e FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 C FR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 1.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Center Stage Videos, operator of an Un manned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation R egulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducte d within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. This request for exemption is similar, if not identical, to many previously submi tted requests that have received exemption.

Commercial operation of an UAS, as described herein , which are equipped with camera(s) and sensors, would operate in the following manner: 1. Aerial photography and/or video for public and/o r private use in Real Estate sales. 2. Aerial video and/or photography for public and/o r private use including public events, and cinematography. 3. Aerial photography of residential/commercial str uctures under contract with the owners or local government authority.

As described fully below, the requested exemption w ould permit the operation of a UAS under controlled conditions in the NAS that would be a) l imited b) controlled c) predetermined and d) will provide safety enhancements to the already safe ope rations in the industry presently using conventional aircraft. Approval of this exemption w ould thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrato r’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

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The name and address of the applicant is: Center Stage Videos

Attn: Matthew T Wise

Ph: 817-490-1599 Email: matt@centerstagevideos.com Address: 7517 Keith Lane Sachse, TX 75048

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b)

14 CFR 61.3 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

Center Stage Videos will operate a two models of sU ASs, the DJI Phantom 2 Vision + and the Cheerson CX-20. Each sUAS will be powered using lit hium polymer batteries and controlled with a remote transmitter operating on 2.4Ghz or 5.8Ghz ba nd. The applicant will operate the UAS in line of sight within a closed off and predetermined area ow ned and/operated by the property representative.

Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surr ounding the proposed operations and the public benefit, reduction in environmental impacts, includ ing but not limited to reduced emissions and noise, the grant of the requested exemption is in the publ ic interest. Accordingly the applicant requests tha t the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalen t or higher level of safety because operations will further enhance the safety of the persons and/or pr operty using conventional aircraft.

The applicant agrees to adhere to the following lim itations and conditions when conducting commercial operations under the FAA issued exemptio n.

1. The UAS will weigh less than 55 lbs. 2. The UAS will have a maximum operating speed of n o more than 50mph.

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3. Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer (VO). 4. The UAS pilot will be a designated Pilot in Comm and (PIC) and hold at least a Commercial

Pilot’s Certificate. 5. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 6. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight t ime whichever occurs first. 7. Flights will be operated at an altitude of no mo re than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform f rom which filming is planned. 8. A briefing will be performed regarding the plann ed UAS operations prior to each day’s flight consisting of all the days’ production activities. 9. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 10. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled a irport unless the respective airports will be contacted advising them of the estimated flight tim e, flight duration, elevation of flight and other pertinent information and approval is given. 11. The operator will obtain verbal and/or written consent of all persons involved with the planned operation and ensure that only consenting persons w ill be allowed within the flight operation

area. 12. The PIC and VO will have been trained in operat ion of UAS. 13. The PIC and VO will be able to communicate by v oice at all times.

14. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre-determined l ocation within a designated location and land autonomously. 15. The UAS will have the capability to abort a fli ght in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, est ablishes 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 u tilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent l evel 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, operation al capability, and proximity to airports and populated areas of the particular UAS. In all cases , an analysis of these criteria demonstrates that t he UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or sa fer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certifi cate without the restrictions and conditions propos ed.

The UAS to be operated hereunder is less than 55 lb s. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flamma ble liquid fuels, and operates exclusively within a secured and designated area. These safety enhanceme nts provide a greater degree of safety to the public and property owners than conventional operat ions conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates

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that there is no credible threat to national securi ty posed by the UAS, 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 aircraf t or experimental or provisionally certificated air craft, the operator must also display on that aircraft nea r each entrance to the cabin, cockpit, or pilot sta tion,

in letters not less than 2 inches nor more than 6 i nches high, the words "limited," "restricted," "lig htsport," "experimental," or “provisional," as applic able.

Even though the UAS will have no airworthiness cer tificate, 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 UAS, two-inch lett ering will be impossible. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”

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

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilo t in command of an aircraft that is carrying passenge rs or property for compensation or hire.

Center Stage Videos may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots , passengers or property. The risks attendant to the operation of UAS is far less than the risk leve ls inherent in the commercial activities outlined i n 14 CFR 61. The pilots used by Center Stage Videos poss ess current ATP Certificates and have more than 1 year experience in the operation of sUASs. C enter Stage Videos will not utilize pilots with les s than Commercial Certificates at any time during com mercial operations.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy conditio n.

As there will be no airworthiness certificate issue d for the aircraft, should this exemption be grante d, no FAA regulatory standard will exist for determini ng airworthiness.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Man ual in the Aircraft. Section 91.9 (b) (2) provides: No person may operat e a U.S.-registered civil aircraft ... (2) For whic h an Airplane or Rotorcraft Flight Manual is not requ ired by §21.5 of this chapter, unless there is available in the aircraft a current approved airpla ne or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinatio n thereof.

The UAS, given its size and configuration has no ab ility or place to carry such a flight manual on the aircraft, not only because there is no pilot on boa rd, but because there is no room or capacity to car ry

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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 UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action

. This regulation requires each pilot in command to t ake certain actions before flight to insure the saf ety of flight. As FAA approved rotorcraft flight manual s will not be provided for the aircraft an exemptio n will be needed.

The PIC will review weather, flight battery require ments, and perform a safety check of the area of intended flight to ensure the flight can be conduct ed safely.

14 C.F.R. §91.119: Minimum Safe Altitudes

. Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the helicopter complies with any route or altitudes pre scribed for helicopters by the FAA.

As this exemption is for a UAS 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 planned, an exemption may be needed to allow such o perations. As set forth herein, the UAS will never operate at higher than 400 AGL with the excep tion that in circumstances where the UAS is used to survey or photograph a structure whose heig ht exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buil dings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved giv en the size, weight, speed of the UAS as well as th e location where it is operated. No flight will be ta ken without the permission of the property owner or

local officials. Because of the advance notice to t he property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations.

Compared to flight operations with aircraft or roto rcraft 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 ai rcraft operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must compl y with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an a ircraft to maintain cruising altitude by reference to

an altimeter that is set “...to the elevation of th e departure airport or an appropriate altimeter set ting available before departure.”

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will b e achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirm ing the altitude of the launch site shown on the GP S altitude indicator before flight.

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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beg inning “a flight in an airplane under VFR condition s unless (considering wind and forecast weather condi tions) there is enough fuel to fly to the first poi nt of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for a t least 30 minutes; or (2) At night, to fly after tha t for at least 45 minutes.”

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS f lights 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 twiligh t

VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §9 1.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly control led area where only people and property owners or official representatives who have signed waivers wi ll be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Sect ion 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limi ting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted . Applicant believes that an equivalent level of sa fety can be achieved by limiting flights to 30 minutes o r 25% of battery power— whichever happens first. This restriction would be more than adequate to ret urn the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircr aft Certification and Registration The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may o perate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certif icate. . . .

(b) No person may operate a civil aircraft unless t he airworthiness certificate required by paragraph (a) of this section or a special flight authorizati on issued under §91.715 is displayed at the cabin o r cockpit entrance so that it is legible to passenger s or crew.

The UAS fully loaded weighs no more than 55 lbs. an d 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 t he UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have imme diate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 41 7(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 betw een required inspections, except as provided in paragraph (c) of this section, have discrepancies r epaired as prescribed in part 43 of this chapter... ,” and others shall inspect or maintain the aircraft i n compliance with Part 43.

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Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenan ce will be accomplished by the operator pursuant to the flight manual and operating handbook. An equiva lent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, an d 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.

Additional Information Matthew T Wise has been invo lved in the building and piloting of remote controlled aircraft for more than 5 years. Addition ally Mr. Wise holds an ATP and is a 121 Designated Examiner for a large regional jet operation. Center Stage Videos second pilot has been involved in the building and piloting of remote controlled aircraft for more than 10 years and he also holds an ATP certificate and is a Check Airman at the same regio nal operation.

Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exempt ions allowing the commercial operation of the applicant’s UAS.

Sincerely,

Matthew T Wise