U.S.	Department	of	Transportation,	Docket	Operations	

West	Building	Ground	Floor,	Room	W12-140

1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590	

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act		of 2012	

To	Whom	It	May	Concern:	

													

					We	are	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	and	

the	procedures	contained	in	14	C.F.R.	Press	Pause	Films,	LLC	is	a	proponent	of	the	

recently	released	docket	no.:	FAA-2015-0150;	Notice	No.	15-01	and	will	abide	by	

and	assist	in	the	development	of	all	proposed	rules	but	seeks	relief	from	14	C.F.R.	

until	further	protocols,	standards	and	tests	are	established.	Press	Pause	Films,	LLC

is	dedicated	to	the	development	of	unmanned	aircraft,	specifically	multi-rotor	

aircraft	(aerial	vehicles	with	a	minimum	of	four	((4))	counter-rotating	propellers)	

which	are	inherently	stable	with	the	ability	to	hover	in	place,	and	safety/flight	

procedures.	Greg	H.	Bollinger,	CEO,	Press	Pause	Films,	LLC	seeks	relief	from	

specific	procedures	contained	in	14	C.F.R.	

					Press	Pause	Films,	LLC	has	received	requests	of	high	definition	aerial	

photography	from	numerous	entities,	that	pertain,	but	are	not	limited	to;	Real	

Estate,	Wildlife	Conservation,	and	closed-set	filming.	Greg	H.	Bollinger,	owner	and	

operator	of	small	unmanned	multi-rotor	aircraft,	seeks	relief,	so	the	he	may	operate	

his	small/lightweight	unmanned	aircraft	systems	commercially	in	airspace	close	to	

airspace	regulated	by	the	FAA	as	required	by	Section	333.	

			 Press	Pause	Films,	LLC	exemption	request	would	permit	its	operation	of	small,	

lightweight,	unmanned	(remotely	controlled	within	line	of	sight)	multi-rotor	aerial	

systems	in	tightly	controlled	and	limited	airspace.	Predetermined,	specifically	

marked	areas	of	operation,	private	property	locations	that	correspond	or	surpass	

current	safety	protocols	will	allow	Press	Pause	Films,	LLC	to	operate	within	

current	safety	parameters	and	to	aid	in	the	development	of	new	protocols	being	

implemented.	As	identified,	amateurs	with	no	flight	experience,	safety	plan	or	

controls	in	place	to	prevent	catastrophe	legally	operate	similar	lightweight,	remote	

controlled	multi-rotors.	Press	Pause	Films,	LLC	is	developing	plans	to	monitor,	

evaluate	and	implement	all	of	its	UAS’s	safely.	

The	plans	include	but	are	not	limited	to:	pre-flight	visual	inspection,	pre-flight	

mechanical	inspection,	in-flight	mechanical	test,	maintaining	a	visual	of	the	aircraft	

and	a	flight	log.	

• • Pre-flight	visual	inspection	includes	examination	of;	propellers,	motors,	

electrical	components	and	parts	of	the	frame	for	chips,	cracks,	burns	or	any	

other	damage.	

• • Pre-flight	mechanical	inspection	is	powering	on	the	aircraft,	transmitter(s)	

and	receiver(s)	–	checking	video	feed	and	throttling	up	from	3rd	person	
point-of-view	without	takeoff	to	ensure	function	of	drive	components	

(propellers,	motors	and	speed	controllers).	

• • In-flight	mechanical	test	is	done	from	3rd	person	point-of-view	(pilot	

watches	the	aircraft)	at	low	altitude	(eye	level)	–	the	pilot	puts	maximum	

input	of	pitch,	roll,	yaw	and	throttle	sharply	into	transmitter	to	ensure	all	

axis	of	aircraft	are	fully	capable.	

• • Maintain	visual	of	aircraft	through	3rd	person	(pilot	watches	aircraft)	

operation	or	by	using	a	spotter	during	1st	person	(pilot	sees	point-of-view	of	

aircraft)	operation.	

• • A	flight	log	documents	the	pilot	in	control,	spotter,	weather,	area	of	

operation	and	purpose	of	flight.	

					To	date,	Press	Pause	Films,	LLC	has	rejected	all	offers	to	work	with	

interested	parties	on	locations	within	the	United	States,	to	ensure	it	is	in	

compliance	with	any	applicable	FARs.	It,	like	other	applicants,	has	done	so	

despite	Judge	Patrick	G.	Geraghty's	decision	in	the	Raphael	Pirker	matter	and	

his	reasoning	that	no	FARs	prohibits	the	use	of	small,	unmanned	multi-rotor	

aircraft	or	lightweight	UASs	like	those	flown	by	other	peer	companies.	

							Granting	Press	Pause	Films,	LLC	request	unites	with	the	Secretary	of	

Transportation's	responsibilities	to	not	only	integrate	UASs	into	the	national	

airspace	system,	but	to	"	...	establish	requirements	for	the	safe	operation	of	

such	aircraft	systems	[UASs]	in	the	national	airspace	system"	under	Section	

333(c)	of	the	Reform	Act.	Further,	Press	Pause	Films,	LLC will	conduct	its	

operations	in	compliance	with	the	protocols	described	herein	or	as	

otherwise	established	by	the	FAA.	

							Granting	Press	Pause	Films,	LLC	exemption	would	benefit	the	public	in	

that	Congress	has	already	pronounced	that	it	is	in	the	public's	interest	to	

integrate	commercially	flown	UASs	into	the	national	airspace	system,	hence	

the	passing	of	the	Reform	Act.	Press	Pause	Films,	LLC	will	conduct	research	

into	safe	UAS	operations	for	every	flight	of	its	UASs.	Flight	data,	visual	

inspections,	recorded	observations	and	flight	analyses	will	be	compiled	to	

further	enhance	current	safety	protocols.	Allowing	Press	Pause	Films,	LLC

to	log	more	flight	time	directly	relates	to	its	research	and	its	ability	to	further	

enhance	current	safety	measures.	The	public	has	critical	interest	in	reducing	

the	danger	and	emission	associated	with	current	aerial	cinematic	capture	

methods,	namely,	full	size	helicopters.	

					Press	Pause	Films,	LLC	respectfully	requests	the	grant	of	an	exemption	

allowing	it	to	operate	small,	lightweight,	remote	controlled	multi-rotor	UASs	

in	Class	G	airspace.	
The	specific	sections	of	Title	14	of	the	Code	of	Federal	Regulations,	Press	

Pause	Films,	LLC	requests	exemption	from:	

14	CFR	21;	14	C.F.R.	45.23(b);	14	CFR	61.113	(a)	&	(b);	14	C.F.R.	91,	et	seq.;	

14	CFR	407	(a)(1);	14	CFR	409	(a)(2);	and,	14	CFR	417	(a)	&	(b).	

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;14	CFR	

61.113	(a)	&	(b);	91.7	(a);91.9	(b)	(2);91.103(b);	91.119;	91.121;	91.203(a)	&	

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

						The	Extent	of	Press	Pause	Films,	LLC	Seeks	and	the	Reason	It	Seeks	Such	Relief:	

Press	Pause	Films,	LLC	submits	this	application	in	accordance	with	the	Reform	Act,	

112	P.L.	95	§§	331-334,	seeking	relief	from	any	currently	applicable	FARs	operating	

to	prevent	Press	Pause	Films,	LLC	contemplated	commercial	photography,	

research	and	other	flight	operations	within	the	national	airspace	system.	The	

Reform	Act	in	Section	332	provides	for	such	integration	of	civil	unmanned	aircraft	

systems	into	our	national	airspace	system	as	it	is	in	the	public's	interest	to	do	so.	

Press	Pause	Films,	LLC	lightweight	UASs	meet	the	definition	of	"small	unmanned	

aircraft"	as	defined	in	Section	331	and	therefore	the	integration	of	Press	Pause	

Films,	LLC	lightweight	UASs	are	expressly	contemplated	by	the	Reform	Act.	Press	

Pause	Films,	LLC	would	like	to	operate	its	lightweight	UASs	prior	to	the	time	period	

by	which	the	Reform	Act	requires	the	FAA	to	promulgate	rules	governing	such	craft.	

					The	Reform	Act	guides	the	Secretary	in	determining	the	types	of	UASs	that	may	

operate	safely	in	our	national	airspace	system.	Considerations	include:	

					The	weight,	size,	speed	and	overall	capabilities	of	the	UAS;	Whether	the	UAS	will	

be	operated	near	airports	or	populated	areas;	and,	whether	the	UAS	will	be	

operated	by	line	of	sight.	

112	P.L.	95	§	333	(a).	Each	of	these	items	militates	in	favor	of	an	exemption	for	

Press	Pause	Films,	LLC.	

					Press	Pause	Films,	LLC	UASs	utilizes	four	counter-rotating	propellers	for	precise	

control	and	stability.	They	each	weigh	less	than	25	pounds,	including	photography	

or	other	equipment.	Each	of	Press	Pause	Films,	LLC	small	unmanned	aircraft	are	

designed	to	primarily	hover	in	place	and	operate	at	less	than	a	40	knot	maximum	

speed.	They	are	capable	of	vertical	and	horizontal	operations	but	operate	only	

within	the	line	of	sight	of	the	remote	control	pilot.	In	addition	to	the	remote	control	

pilot,	Press	Pause	Films,	LLC	uses	a	spotter	and	a	technician,	such	that,	at	

minimum,	two	Press	Pause	Films,	LLC	personnel	govern	the	safe	flight	of	an	Press	

Pause	Films,	LLC	aircraft	at	all	times.	
					Utilizing	battery	power	and	not	combustible	fuels,	flights	generally	last	between	

two	and	twenty	minutes.	Press	Pause	Films,	LLC	does	not	operate	its	UASs	with	

less	than	twenty	five	percent	battery	capacity.	Safety	systems	in	place	include	a	GPS	

mode	that	allows	Press	Pause	Films,	LLC	UASs	to	hover	in	place	if	communication	

with	the	radio	control	pilot	is	lost	and	then	slowly	descend	the	aircraft	until	landing.	

Further,	Press	Pause	Films,	LLC	aircraft	are	programmed	to	slowly	descend	when	

twenty	five	percent	battery	capacity	has	been	reached.	

				Press	Pause	Films,	LLC	does	not	operate	its	UASs	near	airports	and	generally	

does	not	operate	them	near	populated	areas.	Press	Pause	Films,	LLC	only	operates	

its	UASs	in	predetermined	areas	and	only	in	compliance	with	FAA	regulations.	

				Press	Pause	Films,	LLC	operation	of	its	fleet	of	small,	unmanned	aircraft	will	not	

"create	a	hazard	to	users	of	the	national	airspace	system	or	the	public."	112	P.L.	95	§	

333	(b).	Given	the	small	size	and	weight	of	Press	Pause	Films,	LLC	UASs,	combined	

with	their	superior	maneuverability	and	operation	in	well-controlled	areas,	Press	

Pause	Films,	LLC	aircraft	lay	within	Congress's	contemplated	safety	zone	when	it	

promulgated	the	Reform	Act	and	the	corresponding	directive	to	integrate	UASs	into	

the	national	airspace	system	Press	Pause	Films,	LLC	aircraft	do	not	pose	any	threat	

to	the	general	public	or	national	security.	

			The	FAA	has	the	authority	to	issue	the	exemption	to	Press	Pause	Films,	LLC

pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726	(1958),	as	amended	(the	"Act").	

Commercial	and	Public	Benefits	

					Granting	Press	Pause	Films,	LLC	exemption	request	furthers	the	public	interest.	

First,	Congress	has	already	pronounced	that	it	is	in	the	public's	interest	to	integrate	

commercially	flown	UASs	into	the	national	airspace	system,	hence	the	passing	of	the	

Reform	Act.	Second,	Press	Pause	Films,	LLC	conducts	research	into	safe	UAS	

operations	every	time	it	flies	one	of	its	UASs.	Flight	data,	visual	inspections,	

recorded	observations	and	flight	analyses	are	compiled	to	further	enhance	current	

safety	protocols.	Allowing	Press	Pause	Films,	LLC	to	log	more	flight	time	directly	

relates	to	its	research	and	its	ability	to	further	enhance	current	safety	measures.	

Third,	the	public	has	an	interest	in	reducing	the	danger	and	emission	associated	

with	current	aerial	cinematic	capture	methods,	namely,	full	size	helicopters.	Press	

Pause	Films,	LLC	UASs	are	battery	powered	and	create	no	emissions.	If	an	Press	

Pause	Films,	LLC	UAS	crashes	there	is	no	fuel	to	ignite	and	explode.	The	impact	of	

Press	Pause	Films,	LLC lightweight	UASs	is	far	less	than	a	full	size	helicopter,	

despite	the	statistically	noteworthy	safety	record	of	full	size	helicopters	used	in	

aerial	picture	capture.	The	public's	interest	is	furthered	by	minimizing	ecological	

and	crash	impacts	by	permitting	aerial	photography	capture	through	Press	Pause	

Films,	LLC	lightweight	UASs.	
					Progression	of	the	arts	and	sciences	has	been	fundamental	to	our	society	since	its	

inclusion	in	the	United	States	Constitution.	Indeed,	Congress	mandated	the	

integration	of	UASs	into	our	national	airspace	system,	in	part,	to	achieve	

progression	in	this	noteworthy,	and	inevitable,	field.	Permitting	Press	Pause	Films,	

LLC	to	immediately	fly	within	the	United	States	furthers	these	objectives.	Whether	it	

is	the	combination	of	scientific	discoveries	applicable	to	societal	advancement	

(including	those	drawing	upon	architecture,	physics,	engineering	and	cultural	

inclusiveness)	to	advancements	in	publicly	usable	technologies	or	advancements	in	

equipment	available	to	law	enforcement	personnel/first	responders	that	does	not	

cost	millions	of	dollars,	granting	Press	Pause	Films,	LLC	exemption	request	

substantially	furthers	the	public's	interest	in	ways	known	and	currently	unknown.	

Reasons	Why	Press	Pause	Films,	LLC	Exemption	Will	Not	Adversely	Affect	Safety	

Or	How	The	Exemption	Will	Provide	a	Level	of	Safety	At	Least	Equal	To	Existing	

Rule:	

				Press	Pause	Films,	LLC	exemption	will	not	adversely	affect	safety.	Quite	the	

contrary,	for	the	reasons	stated,	supra,	permitting	Press	Pause	Films,	LLC	to	log	

more	flight	time	in	FAA	airspace	will	allow	Press	Pause	Films,	LLC	to	innovate	and	

implement	new	and	as	of	yet	undiscovered	safety	protocols.	In	addition,	Press	

Pause	Films,	LLC submits	the	following	representations	of	its	flight	standards:	

•	Press	Pause	Films,	LLC	UASs	weigh	less	than	25	pounds	complete	with	small,	

high-definition	cameras	like	the	GoPro	or	Canon	T3i;

•	Press	Pause	Films,	LLC	only	operates	its	UASs	below	400	feet;

•	Press	Pause	Films,	LLC	UASs	only	operate	for	2-25	minutes	per	flight;	

•	Press	Pause	Films,	LLC	lands	its	UASs	before	they	reach	25%	battery	power;

•	Press	Pause	Films,	LLC	remote	control	pilots	operate	Press	Pause	Films,	LLC

UASs	by	line	of	sight;

•	Press	Pause	Films,	LLC	remote	control	pilots	have	video	backup	and	nearest	

airfield(s)	contact	information	should	they	somehow	lose	sight	of	the	UAS;

•	Press	Pause	Films,	LLC	staffs	each	flight	with	a	remote	control	pilot,	technician	

and	spotter	with	communication	systems	enabling	real	time	communication	

between	them;

•	Press	Pause	Films,	LLC	UASs	have	GPS	flight	modes	whereby	they	hover	and	then	

slowly	land	if	communication	with	the	remote	control	pilot	is	lost	or	battery	power	

is	below	25%;

•	Press	Pause	Films,	LLC	actively	analyses	electronic	flight	data	and	other	sources	

of	information	to	constantly	update	and	enhance	safety	protocols;

•	Press	Pause	Films,	LLC	only	operates	in	secured	areas	that	are	controlled,	are	

away	from	airports	and	highly	populated	areas;

•	Press	Pause	Films,	LLC	only	operates	during	daylight	hours;

•	Press	Pause	Films,	LLC	conducts	extensive	pre-flight	checks,	boundaries	and	

awareness	prior	to	flight,	during	which	safety	carries	primary	importance;

•	Press	Pause	Films,	LLC	always	obtains	all	necessary	permissions	prior	to	
operation;	and,	Press	Pause	Films,	LLC has	procedures	in	place	to	abort	flights	in	

the	event	of	safety	breaches	or	potential	danger.	

Press	Pause	Films,	LLC	provides	a	level	of	safety	at	least	equal	to	existing	rules,	

and	in	nearly	every	instance,	greater	than	existing	rules.	It	is	important	to	note	that	

absent	the	integration	of	commercial	UASs	into	our	national	airspace	system,	

helicopters	are	the	primary	means	of	aerial	photography.	While	the	safety	record	of	

such	helicopters	is	great,	it	is	far	safer	to	operate	a	battery	powered	lightweight	

UAS.	First,	the	potential	loss	of	life	is	diminished	because	UASs	carry	no	people	on	

board	and	Press	Pause	Films,	LLC	only	operates	them	in	specific	areas	away	from	

mass	populations.	Second,	there	is	no	fuel	on	board	a	UAS	and	thus	the	potential	for	

fire	or	explosions	is	greatly	diminished.	Third,	the	small	size	and	extreme	

maneuverability	of	Press	Pause	Films,	LLC	UASs	allow	remote	control	pilots	to	

avoid	hazards.	Also,	Press	Pause	Films,	LLC	UASs	noise	emissions,	compared	to	

today’s	helicopters,	are	drastically	lower.	Lastly,	given	their	small	size	and	weight,	

even	when	close	enough	to	capture	images,	Press	Pause	Films,	LLC	UASs	need	not	

be	so	close	to	the	objects	they	are	focused	on.	Accordingly,	Press	Pause	Films,	LLC

UASs	will	operate	at	and	above	current	safety	levels.	

Summary	The	FAA	May	Publish	in	the	Federal	Register	

					Part	21	prescribes	the	procedural	requirements	for	issuing	and	changing	design	

approvals,	productions	approvals,	airworthiness	certificates,	and	airworthiness	

approvals.	

					14	C.F.R.	21,	Subpart	H,	entitled	Airworthiness	Certificates,	sets	forth	

requirements	for	procurement	of	necessary	airworthiness	certificates	in	relation	to	

FAR	§	91.203(2)(b,	c,	&	d)	&	91.317(f)(2),	(g),	(j)(1	&	2).	The	size,	weight,	speeds,	

flight	maneuvers	and	controlled	operational	area	of	Press	Pause	Films,	LLC UASs	

permits	exemption	from	Part	21	because	Press	Pause	Films,	LLC UASs	meet	an	

equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	Act.	The	FAA	is	

authorized	to	exempt	aircraft	from	the	airworthiness	certificate	requirement	under	

both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	of	the	Reform	Act.	Both	pieces	of	

legislation	permit	the	FAA	to	exempt	UASs	from	the	airworthiness	certificate	

requirement	in	consideration	of	the	weight,	size,	speed,	maneuverability	and	

proximity	to	areas	such	as	airports	and	dense	populations.	Press	Pause	Films,	LLC

multi-rotor	UASs	do	not	carry	passengers	nor	crewmembers,	therefore,	are	not	

designed	with	a	cabin	or	a	cockpit.	Furthermore,	Press	Pause	Films,	LLC UASs	will	

not	be	operating	in	or	out	of	airports	and	in	view	of	the	fact	that	Press	Pause	Films,	

LLC multi-rotor	UASs	are	electrically	powered	by	small	lithium-polymer	(LiPo)	

batteries	and	emit	no	known	emissions	--	fuel	regulations	for	aircraft	do	not	apply.	

Therefore	Press	Pause	Films,	LLC UASs	meet	or	exceed	each	of	these	elements	and	

elements	proposed	in	Docket	No.:	FAA-2015-0150;	Notice	No.	15-01.	Part	107.	

14	C.F.R.	91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	

certificate.	No	such	certificate	will	be	applicable	in	the	form	contemplated	by	the	
FARs.	With	proposed	Docket	No.:	FAA-2015-0150;	Notice	No.	15-1	as	no	such	

certificate	will	be	applicable,	this	Regulation	is	inapplicable.	

14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	

no	pilots	or	passengers,	and	given	the	size	of	the	UASs,	this	Regulation	is	

inapplicable.	An	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	manual	

at	Press	Pause	Films,	LLC flight	operations	center.	The	FAA	has	previously	issued	

exemptions	to	this	regulation	in	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	

9565,	9565B,	10167,	10167A,	10602,	10700	and	32827.	

14	C.F.R.	§	91.121	regarding	altimeter	settings	is	inapplicable	insofar	as	Press	

Pause	Films,	LLC UASs	utilize	electronic	global	positioning	systems	and	internal	

gyroscopes	and	altimeters	to	provide	spatial	coordination.	

14	C.F.R.	§	91.203	(a)	and	(b)	provides	for	the	carrying	of	civil	aircraft	certifications	

and	registrations.	They	are	inapplicable	for	the	same	reasons	described	above	–

with	recently	proposed	Docket	No.;	FAA-2015-0150;	Notice	No.	15-1.	The	

equivalent	level	of	safety	will	be	achieved	by	maintaining	such	quality	assurance	

and	registrations	reports	at	the	Press	Pause	Films,	LLC flight	operations	center.	

					14	C.F.R.	§	45.23:	Marking	of	The	Aircraft.	

					Applicable	Codes	of	Federal	Regulation	require	aircraft	to	be	marked	according	to	

certain	specifications.	Press	Pause	Films,	LLC UASs	are	unmanned	--	they,	

therefore,	do	not	have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	

words	or	phrases.	Further,	two-inch	lettering	is	difficult	to	place	on	such	a	small	

aircraft.	Regardless,	Press	Pause	Films,	LLC will	mark	its	UASs	in	the	largest	

possible	lettering	by	placing	identification	marks	on	its	frame	as	required	by	14	

C.F.R.	§	45.29	(f)	so	that	the	pilot,	technician,	spotter	and	others	working	with	the	

UAV	will	be	identifiable	and	will	see	the	markings.	The	FAA	has	previously	issued	

exemptions	to	this	regulation	through	Exemptions	Nos.	8738,	

10167,	10167A	and	10700.	

					14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC.	

				 Pursuant	to	14	C.F.R.	§§	61.113	(a)	&	(b),	private	pilots	are	limited	to	noncommercial	operations.	Press	Pause	Films,	LLC can	achieve	an	equivalent	or	

superior	level	of	safety	as	achieved	by	current	Regulations	because	Press	Pause	

Films,	LLC UASs	do	not	carry	any	pilots	or	passengers	–	the	operators	will	maintain	

visual	line	of	site	of	UA	and	given	the	size,	weight,	speed,	maneuverability	and	

operating	parameters	of	Press	Pause	Films,	LLC UAS’s	risk	to	people	and	property	

is	reduced.	Further,	while	helpful,	a	pilot	license	will	not	ensure	remote	control	

piloting	skills,	though	Press	Pause	Films,	LLC pilot	vetting	and	training	programs	

will.	Further,	private	pilot	licensees	require	60-70	hours	of	flight	time	–	with	

hundreds	of	hours	of	computer	simulation	and	remote	control	aircraft	[50+	hours	of	
multi-rotor	UAS]	experience	the	person	in	control	of	the	UA	will	operate	Press	

Pause	Films,	LLC UASs	with	the	same	or	more	skill.	Further,	the	risks	attendant	to	

the	operation	of Press	Pause	Films,	LLC UASs	is	far	less	than	the	risk	levels	

inherent	in	the	commercial	activities	outlined	in	14	C.F.R.	§	61,	et	seq	– Press	Pause	

Films,	LLC maintains	visual	of	UA	via	a	spotter,	altitude	of	UA	will	never	exceed	

400ft	AGL.	Thus,	allowing	Press	Pause	Films,	LLC to	operate	its	multi-rotor	UASs	

with	it’s	current	experience	and	standards	meets	the	minimum	safety	requirements	

of	14	C.F.R.	§61.113	(a)	&	(b).	

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

					14	C.F.R.	§	91.119	prescribes	safe	altitudes	for	the	operation	of	civil	aircraft.	It	

allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	As	

proposed	in	Docket	No.:	FAA-2015-0150;	Notice	No.	15-01,	Press	Pause	Films,	LLC

UASs	never	operates	at	an	altitude	greater	than	400	AGL.	Press	Pause	Films,	LLC

will,	however,	operate	its	UASs	at	a	much	lower	altitude	than	proposed	in	Docket	

No.:	FAA-2015-0150;	Notice	No.	15-01,	a	level	of	safety	exceeding	those	in	relation	

to	minimum	safe	altitudes.	Given	the	size,	weight,	maneuverability	and	speed	of	

Press	Pause	Films,	LLC UASs,	an	equivalent	level	of	safety	will	be	achieved.	

						14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	

Inspections.	

					The	above-cited	Regulations	require,	amongst	other	things,	aircraft	owners	and	

operators	to	"have	[the]	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."	These	

Regulations	only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will	not,	

therefore,	apply	to	Press	Pause	Films,	LLC should	its	requested	exemption	be	

granted.	Press	Pause	Films,	LLC conducts	an	extensive	maintenance	program	that	

involves	regular	software	updates	and	constant	mechanical	inspection	for	

assessment	of	any	damaged	hardware.	Therefore,	an	equivalent	or	greater	level	of	

safety	will	be	achieved.	Press	Pause	Films,	LLC has	researched	its	designs.	

Summary	

Press	Pause	Films,	LLC seeks	an	exemption	from	the	following	Regulations:	14	

C.F.R.	21,	subpart	H;	14	C.F.R.	45.23(b);	14	C.F.R.	§§	61.113	(a)	&	(b);	14	C.F.R.	§	91.7	

(a)	&	(b);	14	C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§	91.119;	14	C.F.R.	§	91.121;	14	C.F.R.	§§	

91.203(a)	and	(b);	14	C.F.R.	§	91.405	(a);	14	C.F.R.	§	91.407	(a)(1);	14	C.F.R.	§	

91.409	(a)(2);	and,	14	C.F.R.	§§	91.417	(a)	&	(b)	to	commercially	operate	small	

lightweight	unmanned	aerial	vehicles	in	aerial	photography	and	research	

operations,	to	conduct	its	own	fieldwork	and	to	assist	in	the	development	of	

platforms	for	photographers,	first	responders,	law	enforcement,	and	search	&	

rescue.	
Granting	Press	Pause	Films,	LLC request	for	exemption	will	enhance	safety	

protocols	thereby	reducing	risk	of	incident.	Aerial	photography	relies	primarily	on	

the	use	of	larger	aircraft,	housing	a	crew	and	running	on	combustible	fuel.	Press	

Pause	Films,	LLC aircraft	do	not	house	a	crew	of	pilots	nor	do	they	contain	

combustible	fuel	--	they	are	smaller,	lighter	and	more	maneuverable	than	

conventional	aircraft.	Additionally,	Press	Pause	Films,	LLC aircraft	operate	at	

lower	altitudes	and	will	not	interfere	with	conventional	aircraft.	Press	Pause	Films,	

LLC has	been	analyzing	flight	data,	flight	film	and	other	information	to	compile	

above-standard	safety	protocols	and	the	implementation	of	flight	operations	that	

exceeds	current	procedures	of	safe	flight.	

There	are	no	people	on	board	Press	Pause	Films,	LLC aircraft	therefore	the	

likelihood	of	death	or	serious	bodily	injury	is	significantly	limited.	Press	Pause	

Films,	LLC will	ensure	positive	growth	of	it’s	safety	and	flight	protocols	with	multirotors. Press	Pause	Films,	LLC operation	of	its	UASs,	weighting	less	than	25	pounds	

and	traveling	at	speeds	lower	than	40	knots	in	exclusive	areas	will	provide	at	least	

an	equivalent	level	of	safety	as	that	achieved	under	current	FARs.	

With	current	knowledge	and	experience	and	until	operator	certifications	become	

clearer	Press	Pause	Films,	LLC		respectfully	requests	that	the	FAA	grant	its	

exemption	request	without	delay.	The	FAA	has	the	authority	to	issue	the	exemption	

sought	by	Press	Pause	Films,	LLC pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726	

(1958),	as	amended	(the	"Act").	

																																																																																																																									Respectfully,

																																																																																																																		Greg	H.	Bollinger,	CEO

																																																																																																								Press	Pause	Films,	LLC.

																																																																																																																										1835	e	17th	st			

																																																																																																																					Tulsa,	OK	74104