March 26th,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SW

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;	12	CFR	

61.113	(a)	&	(b);	91.7	(a);	91.9	(b)	(2);	91.103(b);	91.109;	91.121;	91.151(a);	

91.204(a)	&	(b),	91.405	(a); 91.407(a)	(1);	91.409	(a)	(2);	91.417	(a)	&	(b).

Dear	Sir	or	Madam:

Pursuant	to	Sections	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	

(the	Reform	Act0	and	14	C.F.R.	Part	11,	Corvus	Eye	Productions	LLC	(“CEP”),	a	film	

production	company,	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations (“FARs”)	to	allow	commercial	operations	of	its	Small	

Unmanned	Aircraft	Systems	(“sUASs”)	for	aerial	cinematography	for	film	and	

commercial	productions,	aerial	imaging	for	commercial	and	residential	real	estate

use, aerial	imaging	for	safety	and	monitoring	of	secured	and	controlled	

environments, aerial	imaging	for	search	and	rescue	as	well	as	assisting	local	law	

enforcement	and	rescue	crews,	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.

As	detailed	in	this	document	and	the	attached	Flight	Manual,	the	requested	

exemption	would	permit	the	operations	of	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	best	practices	safety	protocols	followed	

by	CEP	at	each	and	every	film	set	or	job	location.	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	systems	in	the	national	airspace	system.”	Section	333(c) of	the	

Reform	Act.

The	Name	and	address	of	the	applicant	is:

Corvus	Eye	Productions	LLC

Jeremiah	Kaynor

PH:	206-853-6919

Email:	jeremiah@corvuseyeproductions.com

Address:	7824	E	Fir	St,	Port	Orchard,	WA	98366

Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	Part	21
14	C.F.R.	45.23(b)

14	C.F.R.	61.113	(a)	&	(b)

14	C.F.R.	91.7	(a)

14	C.F.R.	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	C.F.R.	91.151	(a)

14	C.F.R.	91.203	(a)	&	(b)

14	C.F.R.	91.405	(a)

14	C.F.R.	407	(a)	(2)

14	C.F.R.	417	(a)	&	(b)

1.	STATUTORY	AUTHORITY	FOR	EXEMPTIONS

The	Federal	Aviation	Act	expressly	grants	the	FAA	authority	to issue	exemptions.	

This	statutory	authority	includes	exemption	civil	aircraft,	as	the	term	is	defined	

under	§40101 of	the	Act,	including	sUASs,	from	the	requirement	that	all	civil	aircraft	

must	have	a	current	airworthiness	certificate.

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	

prescribed	under	subsections	(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	SFR	

§91.203(a)(1).

Section	333(b)	or the	Reform	Act	assists	the	Secretary	in	determining	whether	

sUASs	may	operate	in	the	National	Airspace	System	(NAS)	without	creating	a	

hazard	to	the	user,	the	public,	or	a	threat	to	national	security.	In	making	this	

determination,	the	Secretary	must	consider:

• The	sUAS’s	size,	weight,	speed,	and	operational	capability;

• Whether	the	sUAS	operates	within	the	visual	line	of	sight	of	the	operator

• Whether	the	sUAS	operates	outside	the	highly	populated	areas	and	away	

from	close	proximity	to	airports

CEP’s	first	sUASs	multirotor	vehicle,	weights	4 or	fewer	lbs.	including	payload	

and	has	a	maximum	payload	capacity	of	5.5 lbs.	CEP’s	second	sUASs	multirotor	

vehicle,	weights	45 or	fewer	lbs.	including	largest	payload	and	has	a	maximum	

payload	capacity	of	52 lbs.	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	plane	simultaneously.	The	sUASs	will	operate	only	in	the	pilots	visual	

line	of	site	at	all	times	and	will	operate	only	within	the	sterile	area	described	in	the	
Foxtech	K130	manual	and	DJI	Phantom	2	Manual,	attached	as	Exhibit	1	(hereinafter	

“the	Manuals”).	Such	Operations	will	insure	that	the	sUASs	will	“not	create	a	hazard

to	users	or	the	national	airspace	system	or	the	public.”	Reform	Act	Section	333	(b).

Given	the	small	size	of	the sUASs	involved	and	the	restricted	and	sterile	

environment	within	which	they	will	operate,	our	application	falls	squarely	within	

the	zone	of	 safety	(an	equivalent	level	of	safety)	in	which	Congress	envisioned	that	

the	FAA	must,	by	exemption,	allow	commercial	operations	of	sUASs	to	commence	

immediately.	Also	due	to	the	small	size	of	the	sUASs	and	the	low	altitudes	and	

restricted	areas	in	which	our	sUASs	will	operate,	approval	of	the	applications	

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	surrounding	the	proposed	operations,	and	the	significant	public	benefit,	

including	enhanced	safety,	the	grant	of	the	requested	exemptions	is	in	the	public	

interest.	Accordingly,	CEP	respectfully requests	that	the	FAA	grant	the	requested	

exemption	without	delay.

2. PUBLIC	INTEREST

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	in	the	NAS	before completion	of	the	rulemaking	required	under	

Section	332	of	the	Reform	Act.	By	granting	an	exemption	the	FAA	will	fulfill	

Congress’s	intent	of	allowing	UAS	to	operate	with	significant	safety	precautions	in	

low	risk	environments.	

The	use	of	sUASs	to	assist	in	aerial	imaging	in search	and	rescue	can	

significantly	reduce	risk	to	public	safety	workers	as	well	as	civilians.	 aUASa	can	

inspect,	photograph,	and	collect	data	in	and	around	hard	to	get	or	hazardous	areas	

that	otherwise	would	require	personal	to	put themselves	in	danger	to	gather	the	

information.	

In	addition,	having	a	knowledgeable	and	experienced	crew	and	personnel	

working	with	the	sUASs	on	film	productions	sets	as	well	as	capturing	images	for	

real	estate	will	decrease	the	amount	of	inexperienced	pilots	by	giving	the	clients	a	

safer	option	to	go	with.

Additionally,	sUASs	could	replace	the	use	of	helicopters	and	small	aircraft	to	

monitor	sites	and	capture	cinematography.	The	sUASs	we	propose to	fly	in	these	

applications	range	from	45	pounds	to	4	pounds	with	total	payload	and	carry	no	
combustible	material	on	board,	as	opposed	to	the	much	larger	conventionally	

powered	small	aircraft.	Shifting	to	sUASs	from	helicopters	presents	a	marked	safety	

increase	for	our	film	crews	and	the	public.	

Lastly,	sUASs reduce	the	environmental	impact	by	dramatically	decreasing	the	

energy	used	for	aerial	imaging,	data	collection,	and		aerial	cinematography	for	film	

productions.	Our	sUASs	use	rechargeable	lithium	ion	batteries,	as	opposed	to	fossil	

fuels	burned	in	operation	of	small	aircraft	that	are	many	hundreds	of	times	heavier.	

3.	EQUIVALENT	LEVEL	OF	SAFETY

CEP	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	

have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These	

limitations	provided	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	protocols	followed	

on	film	production	sites	and	imaging	and	surveying	operations	conducted	with	

helicopters	and	other	conventional	aircraft.

CEP	will	be	bound	by	the	following	limitations	when	conduction	its	sUAS	

operations	under	an	FAA	issued	exemption:

1. The	sUASs	will	never	exceed	48	pounds	at	any	given	time.

2. Flights	will	be	operated	within	visual	line	of	sight	of	the	pilot.

3. Maximum	total	flight	time	for	each	operational	flight	will	be	20	minutes.	The	

UAS	calculates	battery	reserve	in	real	time	and	will	retire to	its	ground	

station	with	at	lease	20%	battery	power	reserve	should	that	occur prior	to	

the	20	minute	limit.

4. Flights	will	be	operated	at	an	altitude	of		200	feet	AGL,	never	exceeding	the	

400	feet	AGL.

5. Crew	for	the	operations	will	consist	of	the	sUAS	pilot	who	will	keep	the	sUAS	

within	his/her	visual	line	of	sight	at	all	times.

6. The	sUAS	pilot	will	be	trained	in	flight,	operations	and	safety	procedures	as	

detailed	in	the	Flight	Manuals.

7. The	sUAS	will	operate	within	a	confined	“Sterile	Area”	and	will	always	have	a	

establishment	of	a	“Security	Perimeter”	for	the	flight	operations	area.

8. A	briefing	will	be	conducted	in	regards	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	present	for	this	briefing.

9. All	onsite	personnel	will	consent	to	the	UAS	flyover	on	site	by	waiver,	and	the	

operator	will	obtain	additional	verbal	or	written	consent	of	all	persons	whole

will	be	allowed	within	100	feet	of	the	flight	operation.
10. The	pilot	will	have	been	trained	in	operations	of	UASs	generally	and	received	

up-to-date information	on	the	particular	UAS	to	be	operated.

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

obtained.

12. All	required	permissions	and	permits	will	be	obtained	for	territorial,	state,	

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

appropriate	governmental	agencies.

13. If	the	sUAS	loses	communications	or	loses	its	GPS	signal,	it	will	have	the	

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

Perimeter and	land.

14. If	the	sUAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	

obstacles	or	emergencies.

4.	DESCRIPTION	OF	SPECIFIC	REGULATIONS

14	CFR	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	CEP,	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	or	the	particular	UAS.	Our	

small	UAS	will	be	operated	at	low	speed	in	a	controlled	environment,		at	least	five	

miles	from	an	airport	and	more	than	three	miles	from	any	densely	populated	area.	

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	

helicopter)	operating	with	an	airworthiness	certificate	without	the	restrictions	and	

conditions	proposed.

The	sUASs	to	be	operated	hereunder	are	less	than	48 lbs.	fully	loaded,	carries	

neither	a	pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	

fuels,	and	operates	exclusively	within	a	secured	area.	Like	other	civil	aircraft,	

operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	the	

operator,	pursuant	to	the	Manual’s	requirements,	to	provide	cinematography	and	

photography	for	area	of	operations	as	is	currently	done	on	active	film	production	

sets	and	more.	The	local	law	enforcement	as	well	as	the	FAA	will	have	advance	

notice	of	all	operations.
These	safety	enhancements,	which	already	apply	to	civil	aircraft	operated	in	

connection	with	film	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,	applications	of	these	

same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	

posed	by	the	UASs,	due	to	their	size,	speed	of	operation,	location	of	operation,	lack	

of	explosive	materials	or	flammable	liquid	fuels,	and	ability	to	carry	an	external	

load	no	greater	than	18	lbs.

14	C.F.R.	45.23(b):	Marking	of	Aircraft

This	regulation	requires	certain	experimental,	provisionally	certificated	

aircraft,	or	light-sport	category	aircraft	to	be	marked	with	letters	between	2	inches	

and	6	inches	high	“limited,”	“restricted,”	“light-sport,”	“experimental,”	or	

“provisional,”	near	each	entrance	to	a	cabin,	cockpit,	or	pilot	station.

Even	though	the	UAS	will	have	no	airworthiness	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	sUAS,	two-inch	

lettering	will	be	impossible.	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	sUAS	marked	on	its	

fuselage	as	required	by	§45.29	(f)	where	the	pilot,	observer	and	others	working	

with	the	sUAS	will	see	the	identification	of	the	UAS	as	“Experimental.”	The	FAA	has	

issued	the	following	exemptions	to	this	regulation:	Exemptions	Nos.	10700,	8738,	

10167	and	10167A.

14	CFR	61.113	(a)	&	(b):	Private	pilot	privileges	and	limitations:	Pilot	in	

command

Sections	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	pilot	

operating	the	aircraft	to	have	completed	a	UAS	flight-training course	of 100	hours	

before	flying	a	UAS as	recommended	by	the	Manual.		Unlike	a	conventional	aircraft	

that	carries	the	pilot	and	passengers,	the	sUAS	is	remotely	controlled	with	no	living	

thing	or	cargo	on	board.	The	area	of	operation	is	controlled	and	restricted,	and	all	

flights	are	planned	and	coordinated	in	advances.	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	sUAS	as	requested	with	a	pilot	who	has	met	the	minimum	

requirements	recommended	in	the	manual	exceeds	the	present	level	of	safety	

achieved	by	14	S.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	in	

the	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	

contained	in	the Manual	for	maintenance and	use	of	safety checklists	prior	to	each	

flight,	as	set	forth	in	Section	B	and	Section	G,	an	equivalent	level	of	safety	will	be	

provided.	

14	C.F.R.	91.9	(b)(2):	Civil	aircraft	flight	manual,	marking,	and	placard	

requirements

The	sUAS,	given	its	size	and	configurations	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	FAA	has	issued	the	following	exemptions	to	the	regulations:	

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	take	certain	actions	before	

flight	to	ensure	the	safety	of	flight. An	exemption	is	needed	from	this	requirement,	

as	the	pilot	will	take	separate	preflight	actions,	including	checking	for	weather	

conditions,	checking	flight	battery	requirements,	checking	takeoff	and	landing	

distances,	and	all	and	any	other	actions	that	are	required	in	the	Preflight	Checklist	

in	the	Manual.	These	actions	will	provide	an	equivalent	level	of	safety.

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.	

By	design,	sUASs	and	remotely	piloted	aircraft	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	previously	

approved	exemptions	for	aircraft	without	fully	functional	dual	controls.	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,	the	ability	to	

control	the	sUAS	via	radio	signals	from	the	controller,	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	(b)	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.	This	exemption	is	for	a	multirotor	craft	that	

flies	similarly	to	a	helicopter,	with	vertical	take	off	and	vertical	landing,	which will	

typically	operate	at	altitudes	of	200	AGL,	so an	exemption	may	be	needed	to	allow	

such	operations.	The	UAS	will	never	operate	at	altitude	higher	than	400	AGL	and	

will	be	in	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	location	where	it	is	operated.	No	flight	will	be	taken	without	

the	permission	of	the	property	owner	and	local	officials.	Because	if	the	advance	

notices to	the	property	owner	and	any	onsite	personnel,	all	affected	individuals	will	

be	aware	of	the	planned	flight	operations.	Compared	to	flight	operations	with	

aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	52	lbs.	proposed	

herein	and	carrying	flammable	fuel,	any	risk	associated	with	our	operations	is	far	

less	than	those	presently	presented	with	helicopters	and	other	conventional	

aircraft	operating	at	or	below	500	AGL	in	the	film	industry.	In	addition,	the	low	

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

operations	and	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	reference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure	

airport	or	an	appropriate	altimeter	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	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)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR	

conditions.	Our	UAS	is	limited	to	operations	in	sterile	and	controlled	environments	

and	has	a	limited	range	and	flight	time,	which required	an	exemption	from	14	C.F.R.	

91.151	(a).	

The	battery	powering	the	sUAS	provides	approximately	35	minutes	of	powered	

flight.	To	meet	the	30-minute reserve	requirement	in	14	C.F.R.	§91.151,	sUAS	

flights	would	be	limited	to	approximately	5	minutes	in	length. Given	the	limitations	

on	the	UAS’s	proposed	flight	area	and	location	of	its	proposed	operations	within	a	
predetermined	area,	a	longer	time	frame	for	flight	in	daylight	or	night	VFR	

conditions	is	reasonable.	

CEP	believes	that	an	exemption	from	14	C.F.R.	§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	or	reserve	fuel,	does	not	engender	the	type	of	risks	that	Section	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.	

An	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	minutes,	

or	enough	battery	reserve	to	ensure	that	the	sUAS	lands	at	the	grounding	station	

with	at	lease	20%	of	battery	power	(as	determined	by	the	onboard	monitoring	

system	and	the	pilot),	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	exemptions	have	been	granted	to	other	operations,	including	

Exemptions	2689F,	5745,	10673,	and	10808.

14	C.F.R. 91.203	(a)	&	(b):	Carrying	civil	aircraft	certification	and	

registration

The	regulation	provides	in	part:

(a)	Except	as	provided	in	§91.715,	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	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	45	lbs. and	is	operated	without	an

onboard	pilot.	Therefore	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	flight	control	point	where	the	pilot	flight	the	sUAS	will	have	immediate	

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.

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	section	and	Part	43	apply	only	to	aircraft	with	an	

airworthiness	certificate,	these	sections	will	not	apply	to	CEP.	Maintenance	will	be	

accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	

handbook	as	referenced	in	the	Manual.	An	equivalent	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	of	limited	periods	of	time.	If	mechanical	issues	arise	

the	UAS	can	land	immediately	and	will	be	operating	from	no	higher	that	400	feet	

AGL.	As	provided	in	the	Manual,	the	operator	will	insure	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	Federal	Register,	should	it	be	determined	that	publication	is	needed:

Applicant	seeks	and	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;	91.151	(a);	91.203	(a)	&	(b);	91.405	(a);	91.407	(a)	(1);	

91.409	(a)	(1);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate	commercially	a	small	

unmanned	vehicle	(55lbs	or	less)	in	operations	pertaining to	(but	not	limited	to)

professional	cinematography	and	commercial	productions,	aerial	imaging	for	

commercial	and	residential	real	estate	use,	aerial	imaging	for	safety	and	monitoring	

of	secured	and	controlled	environments,		aerial	imaging	for	search	and	rescue	as	

well	as	assisting	local	law	enforcement	and	rescue	crews.	

Approval	of	exemptions	allowing	commercial	operations	of	sUASs	in	our	

industry	enhances	safety	while	reducing	risk.	Manned	aircraft	filming	and	surveying	

creates	a	greater	risk	because	the	craft	are	much	larger,	have	combustible	fuel,	and	

carry	an	onboard	human	pilot.	In	contrast,	a	sUAS	weighing	fewer	than	45	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	will	carry	no	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	45	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	application	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	and	controlled	access	property	with	the	

property	owner’s	prior	consent and	knowledge. Images	taken	will	be	of	individuals	

who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	

where	aerial	photography	and	cinematography	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	operations	within	visual	line	of	sight	and	national	security	– provide	more	than	

adequate	justification	for	the	grant	of	the	requested	exemption	allowing	commercial	

operation	of	the	applicant’s	UASs	in	the	filming	and	photography	industry	pursuant	

to	the	Manual	appended	hereto.	

Sincerely,

Jeremiah	Kaynor

Corvus	Eye	Productions	LLC

Executive	Producer &	CEO