1 October 7 th, 2015

United States Department of Transportation Docket Management System 1200 New Jersey Av enu e SE Washington DC 20590

Re: Exemptio n Request Pursuant To Section 33 3 of the FAA Reform Act of 2012, March 23, 2015,

"Blanket" C O A , and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23 (b); 14

C.F.R. Part 21; 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) (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, EPT, LLC (“EPT” or “Applicant” )

, owner, manager, developer and operator of entertainment production technologies including Small Unmanned Aircra ft Systems (“sUASs”) equipped

to conduct aerial data collection, photogrammetry

, and 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 exemp tion 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 operation s in the film and television industry presently 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 systems in the national airspace system.” Section 333(c) of the Reform Act.

Per 14 C.F.R. § 11.81, t he following information is submitted for consideration in this petition :

Name and address:

EPT, LLC

Attn: Michael

- Ryan Fletchall

6 01 East Charleston Blvd., #100 Las Vegas, NV 89104 Phone: (818) 516

- 6780 Fax: (877) 837

- 1375 Email: entprodtech@gmail.com

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)

1 The conditions proposed 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.2 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) (1)

14 C

. F

. R

. 409 (a) (2)

14 C

. F

. R

. 417 (a) & (b)

EPT believes an exemption from the regulations notes above will be sufficient to conduct the operations described in this exemption request. To the extent that the FAA may deem it necessary, however, EPT also requests an exemption from any regulations ancillary to the foregoing that may be needed to facilitate the desired operations.

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 Secre tary of Tra nsportation to consider whether certain unmanned aircraft systems may operate safely in the N ational A irspace S ystem ( “ NAS ” ) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secr etary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

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

• 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 f or the safe 2 operation of such aircraft in the national airspace system .” Id . § 333 (c) (emphasis added) 2

.

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

au thority 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.

The Administrator may grant an exempt ion from a requirement o f 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

C.F.R. § 91.203 (a) (1).

EPT ’s sUASs are rotorcraft, weigh ing 55 or fewer pounds including payload , energy sources, and equipment . They operate, under normal conditions at a speed of no more than 87 knots and have the capability to hover, a nd move in the vertical and horizontal plane simultaneously. Their signal

transmissions comply with all Federal Communications Commission requirements. They will operate

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 f ulfill the statutory requirements for approval.3 only in line of sight and will operate only within t he sterile area described in the Confidential Motion Picture and Television Flight Operations and Safety Manual (hereinafter “the Manual” ), attached as Exhib it 1 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 that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by e xemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear

dire ction 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, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant

the r equested exemption without delay.

A ircraft and equivalent level of safety

The applicant proposes that the exemption requested herein apply to civil aircraft that h ave the characteristics and that operate with the limitations listed herein. These limi tations 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 sa fe movie and television filming operations conduc ted with conventional aircraft.

These limitations and conditions to which EPT, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The s UAS will weigh less than 55 pounds including payload.

2. Flights will be operated within line of sight of a pilot and/or visual observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer (“VO”)

, and the Camera Operator

. 6. The sUAS P ilot will be an FAA licensed airman with at least a private pilot’s certificate

and third class medical (or valid U.S. driver’s license issued by a state) . The observer will

hold at least a third class medical (or valid U.S. driver’s license is sued by a state) and have attended some ground school.

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. the

Aerial Coordinator and /or VO ), that person can also be designated as PIC.

8. The UAS will only operate within a confined “Sterile Area” as defined in Part A, Section 1.1.7 of the Manual, which requires the establishment of a “Security Perimeter” for the

3 Applicant submits this manual as a Confidential document under 14 C

. F

. R . 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 release under the Freedom of In formation Act 5 USC 552 et.seq.

4 Reform Act Section 333 (b).4 flight operations 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 present for this briefin g. 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 (“FSDO”)

. 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 in the Manual. With the 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 P art B, Section 2.2.1.4 (g) of the Manual.

13. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office within 24 hours. Accidents will be reported to NTSB per their reporting guidelines.

14. Pilot and VO will have been trained in operation of UAS generally and received up

- to

- date information on the particular UAS to be operated as required in Part A, Section 1.2.2.1 and

1.4.4 , and Part C of the Manual.

15. VO and P ilot will at all times be able to communicate by voice and/or text.

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

17. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

18. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to
return to a pre

- determined locat ion within the Security Perimeter and land.

19. 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 and 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, a n 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 demonstr ates 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 cer tificate without the restrictions and conditions proposed.

The sUAS s to be operated hereunder are less than 55 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively w ithin a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance w ith local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in c onnection with5 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, applicat ion of these same criteria demonstrates that there is no credible threat to national security 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 subs tantial 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 must also display on that aircraft near 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 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 “Experiment al” can be placed. Given the size of the sUAV, 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 sUAV marked on its f uselage 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 an d 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 c an 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 oper ate this s UAS. Unlike a conventional aircraft that carries the pil ot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation 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 req uirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associate d with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS 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 in 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 check lists prior to each flight, as

set forth in Part A, Section 1.5.4, 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:6 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 keepin g 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 this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 1060 2, 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 may not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in Part B, Section 2.2.1 of the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing

and takeoff distances and aircr aft 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.

sUASs 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. 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) allow s 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 sUAS that is a rotorcraft and the exempti on requests authority to operate at altitudes up to 400 feet AGL, or not more than 200 feet above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited condition s stated in the Manual, the UAS will never operate at higher than 400 feet AGL. 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 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, all7 affected individuals will be aware of the planned flight operations as set forth in Part B, Section 2.2.1.4 of the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the

maximum 55 pounds 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

feet AGL in the movie industry. In ad dition, the low

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

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121 : Altimeter S ettings

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 show n 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 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 sUAS provides approximately 40 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 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 C.F.R. § 91.151(a) falls within th e 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 representativ es who have signed waivers will be allowed, with less than 30 minutes of 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 sUAS. Additionally, limiting sUAS flights to 10 minu tes would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety 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 exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) & (b): C arrying 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 following:

(1) An appropriate and curren t airworthiness certificate...8 (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 t hat it is legible to passengers or crew.

The UAS fully l oaded weighs no more than 55 pounds 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 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 requi re 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 prescribe d 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 the applicant. Maintena nc e will be accomplished by EPT, pursuant to the POH and

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 for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Ma nual, 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 m aintain 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 publi cation in the Federal Register, should it be determined that publication is need ed:

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; 91.151 (a); 91.203 (a) & ( 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 (55 pounds or less) in motion picture and television operations within the

United States

.

Approval of exemptions allowing commercial operations of sUASs in the film industry within the United

States will enhance safety by reducing risk. Conventional film operations, using jet or pi ston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000 pounds

, carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 pounds and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board.9 The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew and, therefore, will no t expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 pounds , conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemp tions 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 sa fer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. Night operations will also be conducted by sUASs and such operations are fully lighted so that visibility is as though filming was co nducted during daylight hours.

The grant of this exemption request will benefit the public as a whole by provid ing improved safety in both day and night VFR operations with little to no hazards due to sUAS size, spee d and absence of

flammable fuels.

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

.

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 operation within visual line of sight and national security

– provide more than a dequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in the motion picture and television industry pursuant to the Manual appended hereto.

Respectfully submitted,

Michael

- Ryan Fletchall Manag ing Member EPT, LLC