Outlook Entertainment LLC

625 Forest Ave

Havertown, PA 19083

Phone: 610-952-1776

E-Mail: steve@otlk.com

Web: www.OTLK.com

August 17th 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

Dear Sir or Madam:

This application is being submitted on my own behalf without legal council or consulting 

services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Outlook Entertainment, LLC, operator of Small Unmanned 

Aircraft Systems (“SUASs”) equipped to conduct aerial photography and videography, 

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 exemption would permit the operation of 

small, unmanned and relatively inexpensive SUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if 

granted, would allow Outlook Entertainment, LLC to conduct commercial operations of

small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational 

and safety requirements Congress has set forth in Section 333.

Outlook Entertainment LLC is an image processing company that plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Event Photography /Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitoring
- Educational and research operations

- 3-Dimensional Mapping

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil 

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system 

before completion of the (comprehensive) plan and rulemaking required by section 

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operation authorization” if several factors are met. Petitioner meets all requirements to 

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Parts 21

14 C.F.R. 45.23 (b)

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

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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. 91.205 (b)

Unmanned Aircraft System 

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper 

equipment and personnel cost, reduced noise and as such, a much smaller environmental 

impact which promotes public safety. We are petitioning for exemption to enable 

Outlook Entertainment, LLC to operate a DJI Inspire 1, a DJI Inspire S1000, and a DJI 

Phantom 3, all equipped with three-axis gimbals and using High-Def. cameras. These 

SUAS have built- in capability to limit the height it flies above the ground, to limit the 

radius of the distance it flies from the operator and to exclude it from Class B, C and D 

airspace including a no fly zone feature. The Inspire 1 also has the failsafe function of the 

Naza-M autopilot system, which means when the communication between the Main 

Controller and the transmitter is disconnected, the outputs of all command sticks from 

controller will go to the center position. If the GPS signal is good enough, the system will 

automatically trigger Return to Home and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set 

below:
• Outlook Entertainment, LLC will only operate its SUAS in line of sight of a pilot 

and/or observer and will operate at sites that are a 'sufficient distance' from 

populated areas within the sterile area described in the FOPM. Such operations 

will insure that the SUAS will "not create a hazard to users of the national 

airspace system or the public."

• When flying SUAS within 3 miles of an airport, airport operators will be notified 

and the operator will give the right of way to avoid flying in the proximity of fullscale aircraft.

• Maximum flight time for each operational flight will be 45 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to 

the 30 minute limit.

• The SUAS will be programmed so that it will not be operated at an altitude of no 

more than 400 feet AGL, and not more than 200 feet above an elevated platform 

from which filming is planned.

• Minimum crew for each operation will consist of the SUAS Pilot, and Visual 

Observer.

• The SUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal).

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally.

• Given the small size of the SUAS and the restricted sterile environment within

which they will operate, our SUAS operations adhere to the Reform Act's safety 

requirements

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only 20 minutes, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with 

several buildings and large trees. The applicants in the past have chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than many potential 

clients have been able to afford. The benefits of reduced cost and improved

quality of presentation from the UA will be valuable to and benefit many buyers and 

sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders 

nearby who might require assistance, including fire fighters, the police, the sheriff, et al., 

while remaining subject to all limitations cited in this application as we do so.

a. No flight will be made with a Gross weight exceeding 55 pounds; 

b. All operations must occur in FAA Class G airspace at no more than 400 ft. 

AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM 

from the PIC; 
c. All operations must utilize a visual observer (VO). The VO and PIC must 

be able to communicate by voice at all times during a flight operation; 

d. Operations will be restricted to flights over private property with the 

permission of the property owner; 

e. All required permits will be obtained from state and local government 

prior to operation; 

f. Outlook Entertainment, LLC will not operate over densely populated 

areas; 

g. Outlook Entertainment, LLC will not be operating over any open-air 

assembly of people;

h. Outlook Entertainment, LLC will not be operating over heavily trafficked 

roads;

i. Outlook Entertainment, LLC will not be operating within 5 NM of an 

airport or heliport;

We respectfully request exemption under Section 333 to enable Outlook Entertainment, 

LLC to operate efficient, limited, low-risk commercial SAUS operations for the activities 

stated respecting at all times the space and privacy of citizens and property whilst 

keeping our skies safe.

Sincerely,

Stephen McWilliams Scott Barnhill

Outlook Entertainment, LLC Outlook Entertainment LLC

www.OTLK.com www.OTLK.com

steve@otlk.com scott@otlk.com

610.952.1776 410.598.7111
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Outlook Entertainment, LLC requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the 

SUAS System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the DJI Inspire 1, DJI 

Inspire S1000+, and DJI Phantom 3 under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes:

a. Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft.

b. Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since 

the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that 

an experimental certificate would permit our commercial purpose as well. The 

aircraft will not carry persons or property, will not carry fuel, and will only fly 

under strict operational requirements. Combined with the UA's lightweight, being 

constructed primarily of carbon fiber and plastic, we propose that the UA will be 

at least as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. If an experimental airworthiness certificate is not appropriate 

for this application, then we request an exemption of 14 CFR Part 21, Subpart H, 

and the requirement for an airworthiness certificate in general, citing the 

equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations 

provide that each aircraft must display "N" and the aircraft's registration number in letters 

at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, 

cockpit, or pilot station. The SUAS does not have an entrance in which the word

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 
PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous paragraph will 

provide the aircraft's registration information at the ground station. Finally, we will 

display at the ground station a high contrast flag or banner that contains the words 

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft 

will operate within 3/4 NM of the ground station, the banner should be visible to anyone 

that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. The regulation provides that no 

person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for 

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire. Our proposed operations require that the PIC must 

hold at least a Recreational Pilot Certificate issued by the FAA and since the aircraft

cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph 

(b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only

too small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that a current, approved SUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests. The regulation states, "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." The SUAS 

System ground- based control station consists of a small hand-held radio transmitter and 

while it does not offer a second set of "controls", both the student and instructor can, and 

will, operate the single set of controls simultaneously. With both student and instructor 

having "hands-on" the controls during flight, we feel that this technique meets the intent 

91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the SUAS would be photography or 
survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons 

where permission has been obtained and careful pre-flight planning has been performed. 

The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore 

we maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be considered in 

granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain 

cruising altitudes by reference to an altimeter setting available within 100 NM of the 

aircraft. The SUAS will always fly below 400 feet AGL and will not need to maintain

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the launch and recovery point is transmitted via radio from 

the SUAS on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation 

provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that 

for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The SUAV is battery operated and the 

maximum duration of flight from a single battery charge is 12 minutes with a 20% 

reserve. Since the aircraft will never fly more than 3f4 NM from the point of intended 

landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation 

provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight

of 5.3 pounds, the SUAS is too small to carry documentation, does not have an entrance, 

and is not capable of carrying passengers or crew. To obtain an equivalent level of safety 

and meet the intent of 91.203, we propose that documents deemed appropriate for this 

aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certificates be permanently affixed to 

the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, 

Alterations The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with part 39 and 
43. Paragraphs 91.407 and91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. It is

our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. Maintenance performed by the PIC is limited 

to repairing small cracks, replacing a propeller, checking electrical connections and 

updating software and firmware for the on-board computer. All other maintenance will be 

performed by the manufacturer or their designated repair facility. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, construction,

and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

Outlook Entertainment, LLC will be using the SUAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, unmanned 

aerial vehicles offer myriad benefits over the use of full-sized manned aircraft for electric 

power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still 

photography, just to name a few. Replacing significantly larger manned aircraft carrying 

crew and flammable fuel with small UAS carrying no passengers or crew creates a much 

greater margin of safety for the pilots and crew. By granting Outlook Entertainment, LLC 

requested exemptions, the FAA will help drive development of safe and

successful commercial UAS operations and will advance the public knowledge base for 

such operations. Outlook Entertainment, LLC is committed to promoting the UAS 

research efforts of policymakers including the FAA, NASA, DOD and DARPA by 

sharing data from its commercial UAS operations and serving as a resource for future 

UAS research operations. Thus, the FAA has good cause to grant this

Petition.

Conclusion

As pointed out in this application, all the SUASs which our company would use, under 

authorization by the US DOT-FAA, are small, lightweight devices operated within the 

line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with 

aviation activities, unless the air traffic control authorities (ATC) have been notified and 

have authorized each flight within a radius of this distance.

All our SUASs have proven capability for controlled flight. They are devices offered for 

general sale on the market around the world and have often been used as Model Aircraft 

in the USA. We are certain that the studies conducted until now by the FAA, about 

Section 332, Public Law 112-95, 2014, have already provided you with the assurances on 

the airworthiness of SUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and 

Outlook Entertainment, LLC should be permitted to conduct small UAS operations in 

accordance with its manuals and all other operating parameters deemed necessary and 

appropriate by the FAA. The submission of this application and its contents is the best 
demonstration that indeed it is possible to pursue the authorization process so that some 

SUASs may be used for legitimate commercial activities and under reasonably safe 

conditions.

OUTLOOK ENTERTAINMENT, LLC

625 Forest Ave Havertown, PA 19083

E-Mail: steve@otlk.com

Web: www.OTLK.com

Phone: 610.952.1776