Pilot Productions, LLC

Owner, Mason Dunn 704 NW 16 th St. Moore, OK 7316 0 Dear Sir or Madam: Pursuant to Section 33 3 of the FAA Modernization and R eform Act of 2012, (the “Reform Act”), and 14 CFR Part 11, Mason J. Dunn, operator of an Unmanned Aircraft System (UAS), herby applies for an exemption from the listed Federal Aviation Regulations (“FARs”), to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be est ablished by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Providing live video feed to assist with search and rescue operati ons including, but not limited to, emergencies or national disasters, only when the local authorities/government has requested it by contract or donation  Photography/Videography  Cinematography  Real estate  Architecture  Land surveying/mapping/engineering/arc hitecture and other related professional activities  Photography/videography of golf course activities  Field inspections for structures and infrastructures  Television  News gathering/live video feed  Motion pictures  Pipeline inspections  Inspection of reside ntial/commercial utility infrastructure, including, but not limited to, electrical powerlines/right

- a -way, wind turbines, and cell towers  Construction sites  Roof inspections  Solar inspections  Public and private events  Insurance claims  The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airs pace System (NAS) as well as for the protection of the persons and property. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predeter mined and d) will provide safety enhancements to the already sa fe operations in the industry presently using conventional aircraft. Approval of this exemptions would thereby enhance safety and fulfill the Secretary ofTransportation’s (the FAA Administrato r’s) responsibilities to “...establish requirements for the s a fe

operation of such aircraft systems in the National Airspace System.” Regulations from which the exemptions are requested: 14 CFR P art 21 Subpart H 14 CFR 45.23 (B) 14 CFR 61.113 (A) (B) 14 CFR 91.7 (A) 14 CFR 91.9 (B) (2) 14 CFR 91.103 14 CFR 91.109 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) **Pilot Productions, LLC, will operate the D** **JI Phantom 3 Pro ,**  **DJI Inspire 1** The DJI Phantom 3 Pro has a total weight of 1280g or 2 lbs. 13 oz. The dimensions are 40.36cm x 40.36 x 19.05cm or 16 inch x 16 inch x 7.5 inch. Under still air the maximum speed is no more than 16m/s or 35 mph with a cruis ing speed of 11m/s or 25 mph . The DJI Phantom 3 Pro has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Phantom 3 Pro has four motors, Motor Model # DJI 3510, powered by a 4480mAh 4s LiPo Lithium Polymer battery. There are four propellers, Propeller Model # DJI 1345, in use . The DJI Phantom 3 Pro will be controlled with the C3 remote controller with an operation frequency of 2.4GHz – 2.483GHz. The liv e video feed will have an operating frequency of 2.4GHz ISM with maximum range of 1.2 miles. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/or operated by the property representative. **DJI Phantom 3 Pro**  **General Features**  Ready to fly  3 axis camera stabilization  Precision flight and stable hovering  GPS positioning & auto return home  Onscreen real

-time flight parameters  High Definition 4k Camera  Camera tilt control  Film straight down  Supports Adobe DNG RAW  Adobe lens profile support  Camera parameter settings  Album synchronization  FAA no -fly zones locked out via installed software **Transmitter** Operating Frequency: 2.400 GHz – 2.483 GHz

 Communication distance (open area) : CE: 2000m; FCC 2000m  Receiver sensi tivity (1%PER):

- 101dBm +/

- 2dBm  Transmitter power: CE: 16dBm; FCC: 20dBm  Working voltage: 1.2A @ 7.4V  Battery: 6000 mAh LiPo 2s **Camera**  Operating Environment Temperature: 0 C-40C  Max resolution: 4096 x 2162p @ 24/25fps  FOV: 94/85  Sensor size: 1/2.3”  HD recording: 4k p 24/25fps/720p 60fps **DJI Vision**  **APP**  System Requirement of Mobile Device: IOS version 6.0 or above/Android system version 4.0 or above  Mob ile device Support: Recommended : Ipad Air2, Ipad mini, iphone4s, iphone5, iph one5s, ipod touch4, ipod touch5, iphone6 Pilot Productions will also operate a DJI Inspire 1 with a total weight of 2935g or 6 lbs. 47 oz. The dimensions are 438 x 451 x 301mm or 17.24 x 17.75 x 11.85”. Under still air the maximum speed is no more than 22m/s or 50 mph. The DJI I nspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI In spire 1 has four motors, Motor M odel # DJI 3510H . There are four propellers, Propeller M odel # DJI 1345T and is powered by a 22.8 V with 5700 mAh Int elligent Flight Battery {TB48 }. The DJI Inspire 1 will be controlled with the C1 remote controller with an operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an operating frequency of 2.4GHz ISM with maximum range of 1.2 miles. The a pplicant will operate the UAS in line of sight. **DJI Inspire 1**  **General Feature**  Ready to fly  3 - axis camera stabilization  Precision flight and stable hovering  GPS positioning & auto return home  Onscreen real time flight parameters  High definition 4K camera  Camera tilt control  Film straight down  Supports Adobe DNG RAW  Adobe lens profile support  Camera parameter settings  Album Synchronization  FAA no -fly zones installed **Transmitter**  Operating Frequency: 2.400GHz – 2.483GHz  Communication Distance: 2000m; Fcc 2000m Receiver sensitivity : 1%

- 101dBm +/

- 2dBm

 Trans mitter power : CE 16dBm : FCC 20 dBm  Working voltage : 22.8V **Camera**  Operating Environmental Temperature : 0 degrees – 40 degrees C  Resolution : 12.0MP  FOV: 94 degrees  Sensor size : 1//2.3’  HD recording 4K 4096 x 2160P **DJI Vision APP**  System requirement of mobile device: IOS version 6.0 or above/Android system version 4.0 or above  Mobile device support : Recommended : Ipad air2, Ipad mini, iphone4s, iphone5, iphone5s, iphone6. **AIRCRAFT AN D EQUIVALENT LEVEL OF SAFETY**  T he operation limitations proposed for an equivalent or higher level of safety because o perations will further enhance the safety of the persons and /or property using conventional aircraft. These limitations and conditions to which the appl icant agrees to adhere to when conducting commercial operations under the FAA issued exempt ion as set fourth in the flight o perations manual (FOM ) include:  The UAS will weigh less than 55 lbs. **(DJI Phantom 3 Pr o weighs 1280G or 2 lbs. 13 oz./DJI**  **Inspire #1 weighs 2935 grams or 6 lbs. 47 oz.)**   The UAS will have a maximum operation speed of no more than 50 mph.  Flights will be operated within line of sight of the Pilot in Command (PIC), and/or Visual Observer (VO)

.  Maximum flight time for each operational flig ht will be 20 minutes. Flights will be terminated at 25% battery power reserve or 20 minutes of flight time, whichever comes first.  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 filing is planned.  Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) , and may include but not limited to a Camera Operator.  The UAS pilot will be a designated Pilot in Command (PIC) , a nd will take and pass all necessary certifications currently being approved by the FAA administration for commercial use.  A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the day’s production activities.  All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) , only.  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 airport. The DJI Pha ntom 3 Pro and the DJI Inspire 1 , has a built in software for all FAA regulated “No Fly Zones”, and was uploaded by DJI (Feb 2015), for all DJI drones to download and prevent any possible flights o ccurring within no

fly zones.  If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (APR), of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated fligh t time, flight duration, elevation of flight and other pertinent information. The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local flight Standards District Office (FSDO) , n o more than 72 hours but no less than 48 hours from planned operation.  The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operations, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.  The PIC and VO will have been trained in operation of UAS and receive up

-to - date information for the particular UAS to be operated.  The POC and VO will be able to communicate by voice, radios, and /or text at all times.  Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate government agencies.  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 location within a designated location and land autonomously.  The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.20 3 (a) (1)**  Subpart H, entitled Airworthiness Certificates, established 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 b e utilized by th e Applicant, an exemption from P art 21 Subpart 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701 (F ) , and Section 333 of th e R eform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certi ficate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, and analysis of the criteria demonstrates that the UAS operated without an airworthiness certi ficate, 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 certificated without the restrictions and conditions propos ed. The UAS to be operated hereun der is less than 55 lbs. , carries neither a pilot nor passenger, carries no explosives materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operat ions under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide greater degree of safety to the public and pro perty 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 UAS, due to its size, speed of operations, 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 or experimental or provisionally certificated aircraft, the operator mu st also display on that aircraft near each entrance t o 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 airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the “Experimental” can be placed. Given the size of the UAS, 2

- inch lettering will beimpossible. The word “Experimental” will be placed on the fuselage in compliance with § 45.29 (F ). 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 identifications of the U AS as “Experimental”. **14 C.F.R. § 61.113 (A) and (B**  **): Private Pilot Privileges 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 pilot in command of an aircraft that is car rying passengers or property for compensation for hire. An equivalent level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of U AS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation of the UAS. **14 C.F.R. § 91.7 (A** **): Civil Aircraft Airworthiness** The regulations requi re that no person may operate a civil aircraft unless it is in airworth y 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 for maintenance and use of safety check lists prior to each flight 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 p erson may operate a U.S. registered civil aircraft - F or 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 man ual material, markings, and placards, or any combination thereof. The UAS, 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 on board, but because there is no room or capaci ty 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 UAS will have immediate access to it. **14 C.F.R. §91.103: Preflight Action.** This regulation requires watch pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved R otorcraft Flight M anuals will not be provided for the aircraft, an exemption will be needed. This PIC will take all actions as stated in the manufacture FOM in the pre

-flight inspection sections, including but not limited to 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 person 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. 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 flight instruction in experimental aircraft. 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 c ivil 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 route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption request 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 operations. As set forth herein, the UAS will never operate higher th an 400AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure

whose height exceeds 400 ft. AGL, the UAS will not be operated more than 200 ft. above the highest point on the structure. It will however be operated in a restricted area with 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, speed of the UAS as well as the loca tions 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. Compared to flight operations with aircraft or rotorcraft weighing more than the maximum 55 lbs. Proposed herein and the lack of flammable fuel risk associated with these operations is far less than those presently presented wit h conventional aircraft to operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensue separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 C.F.R §91. 121 Altimeter Settings**  . This regulation requires each person operating an aircraft to maintain cruising altitude by referencing to an altimeter that is set “to the elevation of the departing airport or an appropriate altimeter setting available before depa rture” . As the UAS may not have a barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety checklist and live flight data monitoring, confir ming 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 airplan e under VFR conditi ons unless ( considering wind and forecast weather conditions) there is enough fuel to fly to the first intended landing, and, assuming normal cruising 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 UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minute in length. Given the limitati ons 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 twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CRF § 91.151 (A) , falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waiver will be allowed, with less than 30 minutes of reserve fuel, doesn’t not e ngender the type of risks that Section 91.151 (A ) was intended to alleviate given the size and speed for the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant bel ieves that an equivalent level of safety can be achieved by limiting flight to 20 minutes or 25% of battery power, whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limi ted operating area. **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 §91.715, no person may operate a civil aircraft unless it has within it the appropri ate and current airworthiness certificate. (B) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (A) of this 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 UAS. An equivalentlevel of safety will be achieved by keeping these documents at the ground control point where

the pilot flying the UAS will ha ve immediate access to them, to the extent they are applicable to the UAS. **14 C.F.R. § 91.405 (A) (1), 417 (A) (B**  **): Maintenance Inspections.** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in S ubpart E of this part and shall between required inspections, except as provided in paragraph (C ), of this section, have discrepancies repaired as prescribed in P art 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 only 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. An equivalent level of safety will be achieved because the UAS is very limited in size and carry a small payload and operate only in restricted areas for a limited period of time. If m echanical issues arise, the UAS can land immediately and will be operati ng from no higher than 400 feet AGL. The operator will ensure that the U AS 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 th e aircraft and best suited to maintain the aircraft in a n airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer’s User’s Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed. Given the small size of the UAS and the controlled environment provided the propo sed operations will adhere to the Reforms Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant requests that the FAA grant the request exemption with minimum dela y. Thank you for your consideration,

Pilot Productions, L.L.C. Owner, Mason J. Dunn 704 NW 16 th St. Moore, OK 73160 405 - 919 - 7230 Mason3866@yahoo.com