Friday, February 12, 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590



### 1. Contact Name and Information:

Mitten State Productions, LLC Ryan Frederick, Owner 220 Ferguson St. Lansing MI 48912 Phone: (614)207-9956 Email: Ryan@mittenstateproductions.com



### 2. Sections of 14 CFR Requiring Exemption

14 C.F.R. 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) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)



### 3. Extent of Relief Seeked and the Reason for ReliefMitten State Productions is writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that Mitten State Productions, an owner and operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that Mitten State Productions may operate a small lightweight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, Mitten State Productions is experienced in testing and flying UAS for recreational purposes. Mitten State Productions will be using professional grade quadcopter UAS (DJI Phantom 3 Professional) equipped with an internal, extremely high quality camera on a removable 16GB (max 64GB) micro SD card. The Phantom 3

camera shoots full Ultra HD 4K video with 4096x2160 pixel resolution at 24/25 frames per second and 3840x2160 pixel resolution at 24/25/30 frames per second. The Phantom 3 professional is equipped for aerial videography/cinematography to enhance fundraising, event, scientific outreach and product launch videos for researchers at Michigan State University, non-profits and businesses; following exemption and approval by the FAA. These outlined purposes will help promote local economic growth and employment, Increase scientific awareness and increase fundraising potential for lansing area nonprofits.

I, Ryan Frederick, have flown UASs without incident for three and a half years. With continued commitment to safety with each flight, Mitten State Productions’s exemption request would permit operation of lightweight (less than 5 lbs), unmanned (piloted by remote control) UAS(s) in tightly controlled and limited airspace. Mitten State Productions will operate the UAS in predetermined areas away from general public, airports, helipads and vehicular traffic and within property boundaries for fundraising, event scientific outreach and product launch videos. Every pilot of Mitten State Productions will have instilled in them safety protocols and controls in order to avoid and prevent public hazard or catastrophe with UAS operation. This will act to further safety protocols exclusive to lightweight UAS's specific to video and photography usage as recorded flight data and other information gained through permitted flight operations will be shared with the FAA through any required FAA reports to assist with future protocol and safety regulations.

Granting Mitten State Productions’s request comports with the Secretary of Transportation’s responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act. Further, Mitten State Productions will conduct operations in compliance with the protocols described herein or as otherwise established by the FAA.For the reasons stated below, Mitten State Productions, respectfully requests the grant of an exemption allowing to operate light weight, remote controlled UAS’s to enhance fundraising, event scientific outreach and product launch videos for researchers at Michigan State University, non-profits and businesses who cannot afford expensive manned aircraft for the same purpose. Both of these will promote local economic growth through increased employment, increased tax base and more funding for charity and non-profit groups.

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 national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary 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; • 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 for the safe operation of such aircraft in the national airspace system.” Id

. § 333 (c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes UASs, 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 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 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1).

Mitten State Productions’ UASs are rotorcraft, weighting 5 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 40 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will operate only within apredetermined and closed off property area under the permission of the property representative. Such operations will insure that the UASs will “not create a hazard to users of the national airspace system or the public” as per the Reform Act Section 333 (b).

Given the small size of the UASs involved and the restricted 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 exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant UASs will operate, approval of the application 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, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and commercial videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.



### 4. How Request Will Benefit the Public As A Whole:

Aerial videography for business and non-profit use has been traditionally completed with manned fixed wing aircraft and helicopters. Aerial videography is cost prohibitive. Only large businesses and high budget film productions can afford such expenses. This deprives small businesses and small budget film makers from a valuable marketing/ cinematographic tool. Manned aircraft pose more of a threat to both the pilots and the general public due to the size and the combustible fuel held on board than do small UAS, which are low mass and contain no fuel.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system. The multicopters proposed for exemption are battery powered and creates no emissions that can harm the environment. The consequence of a small UAS crashing is far less than a full size helicopter or fixed wing aircraft.

Permitting Mitten State Productions to immediately fly within national air space furthers economic growth. Granting the exemption request substantially furthers the economic impact for the Michigan community by providing important technological advancements to be incorporated into the state’s commercial business. Utilizing UAS technologies,Mitten State Productions will help enhance fundraising, event scientific outreach and product launch videos for researchers at Michigan State University, non-profits and businesses who cannot afford expensive manned aircraft for the same purpose. This will in turn help promote economic growth through employment and tax revenues.



### 5. Aircraft and Equivalent Level of Safety

Mitten State Productions proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations are conducted on closed off property under the permission of the property owner or property representative.

These limitations and conditions to which Mitten State Productions agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh no more than 5 lbs including payload.

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

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 15% battery power regardless of flight time.

4. The UAS will not operate at a flight speed of more 100 mph, particularly because the maximum flight speed of the Phantom 3 is 16 m/s (~36 mph)

5. Flights will be operated at an altitude of no more than 400 feet above ground

level.

6. Minimum crew for each operation will consist of the UAS Pilot, known as the Pilot in Command (PIC), and the Visual Observer (VO).

7. The PIC will have a minimum of 40 hours of flight time with the specified UAS equipment Mitten State Productions operates. The experience of the PIC will be certified by Mitten State Productions through background checks and, if necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). Mitten State Productions will maintain flight logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records of these PICs.

8. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation.

9. A briefing will be conducted in regard to the planned UAS operations prior to each day’s production activities. It will be mandatory that all personnel involvedwith the operational duties of the flight within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District

Office.

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. With the advanced permission of the relevant FSDO, operations at closer range can be approved.

12. PIC and VO will have been trained in the operation of the specific UAS equipment used by Mitten State Productions, and received up-to-date information on the particular UAS to be operated.

13. The PIC designated for any operation will have at least a Class 2 medical

certificate.

14. Visual Observer and PIC will at all times be able to communicate by voice, radio,

and/or text.

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

16. 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.

17. If the UAS loses communication with the PIC or loses its GPS signal, the UAS will have the capability to return to a pre-determined location within the Security Perimeter and land autonomously.

18. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

Mitten State Productions considers safety a foremost requirement with each flight. Our small unmanned aircrafts are designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and to avoid financial loss, we will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows our UASs to hover in place when radio controls are released. When pilot communication is lost, the UAS is designed slowly descend to point of take off. We will not operate our UAS near airports, hospitals, nor police heliports, and will not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. We will be constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach our location or we suspect manned aircraft may approach near our location. Our UASs are capable ofvertical and horizontal operations, and are flown only within line of sight of the PIC. Utilizing battery power rather than combustible fuels, flights generally last between 15-20 minutes, with an altitude under four hundred (400) feet.

14 C.F.R. 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 the Applicant, 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 of the particular UAS. In all cases, 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 rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UASs to be operated hereunder are 5 lbs. or less fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, 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 connection with 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, application 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 inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft An exemption is 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 UAS, two-inch lettering will be very difficult. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer, and others working with the sUAS will see the identification of the UAS as “Experimental”. The FAA has issued the following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and

10167A.

14 C.F.R. § 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 PIC operating the aircraft to have no less than 40 hours of flight time with the specific UAS equipment Mitten State Productions operates. The experience of the PIC will be certified by Mitten State Productions through background checks and, if necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: PAR or PRH). Mitten State Productions will maintain flight logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records of these PICs. The PIC designated for any operation will have at least a Class 2 medical certificate. The risks associated with the operation of the UAS are greatly diminished compared to the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS by a PIC meeting the standards of Mitten State Productions (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

Unlike a conventional aircraft that carries the pilot and passengers, the UASs are 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. Currently there are no pilot licenses that are specific for UAS operators, and no current FAA sanctioned pilot license of any type requires training with, and knowledge of, UAS equipment greater than the requirements Mitten State Productions uses to certify its PICs. Therefore, the requirement of any available FAA sanctioned pilot license to operate a UAS does not make a PIC a more competent operator than one meeting the requirements of Mitten State Productions. Our company hopes the FAA develops a new Pilot License specific for UAS and sUAS commercial operation, one that sets high standards on the quality of pilots and increases the professionalism of our emerging industry. If the FAA does this,

Mitten State Productions's PICs will be some of the first to file for these licenses.

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 for maintenance, and use of safety check lists prior to each flight (summaries listed below), an equivalent level of safety will be provided. Summarized Safety Checklists:

1. Aircraft: All adjustment points will be checked for tightness; all motors and props will be inspected; all wiring will be double checked; all systems will be powered up and checked for errors.

2. Battery: Confirmation will be made that batteries are fully charged and installed/ connected properly.

3. Calibration: Pre-flight motor/gyro calibration followed by confirmation of no errors with the flight and navigation systems.

4. Transmitter: Confirm radio transmitter has sufficient charge, and is both workingproperly and receiving telemetry from the UAS; confirm all switches are in preflight mode.

5. Surroundings/Flight Area: Conduct one last visual inspection of the take-off surroundings and area of airspace UAS will be operating in. Confirm all people in the surrounding areas are associated with the filming being done.

6. Take-off Announcement: Before motors are started the PIC will announce to a designated Representative (person of authority) of the film crew that the UAS is ready to take-off. Only after the Representative has notified all persons within the surrounding areas, and confirmed to PIC that they have clearance to lift-off, will the motors be started and the UAS will conduct its operation.

7. Test Flight: A test flight will be conducted: after any disassembly/reassembly; after replacement of any motors or flight electronics; after any pre-flight or in flight equipment errors that occur not resulting from environmental conditions; very first thing of any commercial operations day before filming begins; if there are any concerns about environmental conditions and potential issues with the flight path.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides that: 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.given the size of the UAS the flight manual will be kept at the ground control point where the PIC flying the UAS 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, and 10602.

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 will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. § 91.109: Flight instruction: Section 91.109 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. UASs 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 is 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) 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. If granted exemption, our UAS will only operate at altitudes of 400 feet AGL and less, or not more than 200 feet above an elevated platform from which filming is planned. The only exception would be in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, wherein the UAS will not be operated more than 100 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 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, all affected individuals will beaware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing more than the maximum 50 lbs. along with 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 AGL in the movie industry. In addition, the low-altitude operations of the UAS 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 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.” Our UAS do not have a barometric altimeter, but instead a GPS altitude read out. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, 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 The batteries powering our UASs provide no more than 30 minutes of powered flight per single charge. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would not be possible due to the reserve requirement being equal to the maximum flight time. 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 twilight VFR conditions is reasonable.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 30% of battery power— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its 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 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 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 5 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS.

An 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 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 sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance and inspections will be done in accordance with the UAS Manufacturer's Manual, and will be performed by employees of Mitten State Productions following the guidelines and practices provided to us by the UAS Manufacturer. An equivalent level of safety will be achieved because these small UASs are very limited in size 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. The PIC 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 PIC 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 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) and (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 (50 lbs or less) in commercial videography operations.

Approval of exemptions allowing commercial operations of UASs in the film industry willenhance safety by reducing risk. Conventional film operations, using jet or pistonpowered 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 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters.) Such aircraft must fly to and from the film location. In contrast, a UASs weighing fewer than 50 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the film set. The UAS 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, weighing less than 50 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 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 controlled environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Additional Views and Information

Mitten State Productions is eager to capitalize on the emerging technological advancements that UAS equipment can provide to the film, television, and photography. It not only provides new cinematography capabilities, but also increased safety over current and past practices that used larger and more dangerous equipment. Our company wants to have the highest levels of safety and professionalism, and one thing essential to this is achieving a path to commercial licensing with the FAA. We believe this will help reduce unsafe practices, discourage improper uses, and improve public perception.Sincerely, Ryan Frederick Owner, Mitten State Productions