235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of FAA Reform Act and Title 14, Code of Federal 

Regulations (14CFR): §§ 61.113 (a) and (b); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)

(1); 91.409(a)(2); and 91.417(a) & (b). 

Dear Sir or Madam: 

Pursuant to 14 CFR pare 11 and Section 333 of the FAA Modernization and Reform Act of 2012 

(“the FMRA”), Center of the Universe Productions DBA COTU Media (referred to herein as 

“Applicant”), developer, operator, servicer, authorized dealer, and solicitor of small 

Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial cinematography operations 

on behalf of businesses operating in markets including insurance, real estate, legal, 

agriculture, infrastructure, motion picture, technology, government, and private security, 

hereby applies for an exemption from the enumerated Federal Aviation Regulations in order to 

allow commercial operation of its sUAS, so long as such operations are conducted within and 

under the conditions stipulated herein or as may be established by the FAA as required by 

Section 333. 

Center of the Universe Productions DBA COTU Media seeks the exemption to retain permitted 

operations of sUAS exist under controlled conditions in airspace which; (1) provide safety 

enhancements to the already safe businesses presently using the conventional aircraft, and; 

(2) thereby limits, controls, and predetermines access to the sUAS. 

Applicant’s Information: 

Center of the Universe Productions DBA COTU Media 

Michael DeLano 

235 E. Broadway Ste 406 

Long Beach, CA 90802 

michael@cotupro.com
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

Table of Regulations in the Petition 

14 CFR § 61.113(a), (b); 14 CFR § 91.119; 14 CFR § 91.121; 14 CFR § 91.151(a); 14 CFR § 

91.405(a); 14 CFR § 91.407(a)(1); 14 CFR § 91.409(a)(2); 14 CFR § 91.417(a), (b). 

The petition for exemption is expressly submitted to fulfill the legislative intent of Section 

333 (a) through (c) of the FMRA. The FMRA directs the Secretary of Transportation to consider 

the issue of UAS operations with respect to the National Airspace System (NAS) prior to the 

maturation of the pending rulemaking required under Section 332 of the FMRA. In resolving 

this issue, the Secretary must determine the type of sUAS which do not create a hazard to 

users of the NAS or public or pose a threat to national security. Such hazardous sUAS’s are 

determined based on the size, weight, speed, operational capability, proximity with respect 

to airports, and the operation of the sUAS within the visual line of sight (VLOS) of the 

operator(s) or spotter(s) partied to the sUAS operations. 

Upon determining such vehicles operate safely, the Secretary establishes requirements for the 

safe operation of such aircraft in the NAS. FRCA §333(a), (c). However, the Federal Aviation 

Act grants an express authority to the FAA to issue exemptions. The federal statutory 

authority on its face included the exempting of civil aircraft (defined under § 40101 of the 

act), which in turn includes sUAS, as per the requirement of all civil aircraft to retain an 

airworthiness certificate. 

An exemption may be granted under subsection (a) or (b) of the aforementioned section, or 

any section 44701-44716 of this title if the Administrator finds the exemption in the public 

interest. 49 U.S.C.A. § 44701 (West 2015). See also U.S.C.A § 44711(a) (West 2015); 49 

U.S.C.A. § 44704 (West 2015) and; 14 CFR § 91.203(a)(1) (West 2015). 

Center of the Universe Productions DBA COTU Media seeks to use rotorcrafts which do 

not exceed 55 pounds (including payload). The rotorcraft operates at an air speed not 

in excess of 55 knots. The rotorcraft will be operated within the VLOS of the operator 

and/or spotter at all times while remaining in a secure area which ensures that the 

sUAS does not create a hazard to users of the NAS or the public at large. FMRA § 

333(b) (West 2015). Center of the Universe Productions DBA COTU Media intention is 

secure environment operations and due to the size of the aircraft provides the “zone 

of safety” which manifests the intentions expressed by Congress when enacting FMRA. 

Id. In addition, with respect to the size and intended use of the sUAS on behalf of the 

applicant, Center of the Universe Productions DBA COTU Media within secure 

environments, approval of the application presents no issue of national security. Here, 

given the express direction of Section 333 of the FRMA, and under the authority of the 

FAA as amended, the secure flight operations of the proposed aerial photography/

filming operations, it stands to reason that public benefit vis-à-vis enhanced safety, 

positive environmental impacts (reduced use of larger manned aircraft), and positive 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

economic impacts support granting of the requested exemption in the interest of the 

public. As a result of the aforementioned, the FAA should by exemption allow Center 

of the Universe Productions DBA COTU Media ’s commercial operations of sUAS to 

commence immediately. Therefore, Center of the Universe Productions DBA COTU 

Media , respectfully requests the FAA grant the requested exemption with haste. 

Specific Relief Requested by Center of the Universe Productions DBA COTU Media ; 

1. Private Pilot Operations under 14 CFR § 61.113(a) and (b)

14 CFR section 61.113(a) and (b) provide limits upon private pilot non-commercial operations. 

14 CFR § 61.113(a), (b) (West 2015). Distinguishable from a conventional manned aircraft, 

which carries a pilot and passengers, the sUAS is operated remotely. Here, the sUAS will not 

carry any persons (pilot or passenger), and the proposed operations can thereby achieve the 

requisite equivalent level of safety of current flight operations. That is to say, the operations 

of the sUAS will be controlled and restricted as all flights will be planned and coordinated 

prior to commencing operations. Thus, the level of control and restriction exceed the 

requirements by a commercial pilot operating a conventional aircraft. In addition, the level of 

restriction aforementioned will so diminish the risk associated with commercial operations 

contemplated when part 61 was drafted that allowing the operation as requested clearly 

exceeds the levels of safety achieved by 14 CFR § 61.113(a) and (b). 

2. Minimum Safe Altitudes under 14 CFR § 91.119

14 CFR section 91.119 proscribes safe altitudes for civil aircraft operations. 14 CFR § 91.119 

(West 2015). Section 91.119 permits helicopter operations in lower altitudes on the condition 

that the helicopter operator complies with the FAA’s relative route and altitude instructions. 

Here, the request is for sUAS rotorcraft operations below 400 feet above ground level or for 

filming operations no more than 200 feet above any platform which filming is planned, as an 

exemption may be necessary for such operations. As set forth herein, Center of the Universe 

Productions DBA COTU Media , applicant, will not operate sUAS in excess of 400 feet at any 

time. As previously mentioned, and equivalent level of safety as intended by congress will be 

achieved due to the size, weight, and speed of the sUAS in addition to the locations where 

the sUAS will be operated. No flight will occur without the consent of the property owner(s) 

and local official(s). Thus, with the consent of the property owner and notice to the 

participants to the aerial photography all affected individuals will be aware of the planned 

sUAS operations. Moreover, the lack of flammable fuel, the nominal size of the sUAS, are 

significantly less than any associated risk with the operation of manned aircrafts at or below 

400 feet above ground level. 

3. Altimeter Settings under 14 CFR § 91.121 

The sUAS in operation does not have a barometric altimeter, but instead functions with Global 

Positioning Satellite altitude data readouts an exemption to 14 CFR section 91.121 may be 

necessary. In pertinent part, “... to the elevation of departure airport or an appropriate 

altimeter setting available before the departure”, requires each operator to maintain cruising 

altitude by virtue of an altimeter that is fixed. 14 CFR § 91.121 (West 2015). Here, the level 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

of safety will most likely exceed the level of safety by confirming the altitude of the launch 

site shown on the GPS readouts prior to any flight operations. 

4. Fuel Requirements for Flight in Visual Flight Rules Conditions under 14 CFR § 

91.151 (a) 

Center of the Universe Productions DBA COTU Media seeks an exemption for under 14 CFR 

section 91.151 (a). Aircrafts are required to retain a 30 minute fuel reserve as per 14 CFR 

section 91.151. 14 CFR § 91.151 (a) (West 2015). However, the batteries powering Center of 

the Universe Productions DBA COTU Media ’s sUAS(s) provide approximately 45 minutes of 

flight time. Therefore in order to meet the requirements set forth under section 91.151(a) 

the sUAS flights would be limited to roughly 15 minutes. Center of the Universe Productions 

DBA COTU Media respectfully asserts an exemption from 14 CFR section 91.151 (a) is 

reasonable as an exemption falls within the scope of previously approved exemption 

petitions. See FAA Exemptions 10673, 268F, 5745, 10808, and 11633. Limiting sUAS flights to 

approximately 15 minutes would greatly reduce the utility for the aerial cinematography for 

which the exemption is sought. Thus, applicant asserts an equivalent level of safety can be 

achieved by limiting flights to 30 minutes or 20 percent of battery power. This restriction 

provide adequate time to return the sUAS to a planned landing zone within the sUAS secure 

operating area. Thus, as per the aforementioned previously approved exemptions the 

applicant seeks similar exempt status from 14 CFR section 91.151 (a). 

5. Maintenance Inspections under 14 CFR § 91.405(a); § 91.409(a)(2); § 91.417(a) and 

(b) 

The enumerated sections and part 43 apply to aircraft with airworthiness certificates, and 

therefore these sections will not apply to the applicant. Moreover, the performance of any 

requisite maintenance will be conducted and logged to ensure that the sUAS remains in 

working order prior to any flight operations. The maintenance logs will be available to the FAA 

upon request. 

Terms and Conditions to which Center of the Universe Productions DBA COTU Media agrees to 

be bound during any and all commercial operations of Small Unmanned Aerial Systems 

1. All aircraft operated in accordance with this exemption will be identified by serial 

number, identification number (N-Number) markings in accordance with 14 CFR part 

45, and registered in accordance with 14 CFR part 47. The sUAS will not at any time 

exceed a weight of 55 pounds or a speed of 55 knots. The sUAS will be programed to 

return to a predetermined landing location in the event that manual control is lost. No 

sUAS operation will exceed thirty minutes of flight time or fifteen percent of total 

battery power remaining, whichever occurs first. 

2. No sUAS operations will be conducted at night as required by 14 CFR section 1.1 and 

all operations will be conducted under weather conditions which are conducive to the 

visual line of sight requirements of safe flight operations. 

3. The operations authorized by this grant of exemption are limited to the following 

aircraft: DJI phantom series, DJI Inspire 1, and DJI s1000. Center of the Universe 

Productions DBA COTU Media will provide serial numbers and registration or proof of 

non-registration (brand new aircraft) of all sUAS upon request by the FAA. 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

4. All flight manuals and general operating manuals will be maintained by Center of the 

Universe Productions DBA COTU Media and will be made available to the FAA upon 

request. Center of the Universe Productions DBA COTU Media will follow the 

procedures as outlined in the flight manuals and general operating manuals and will 

track any revisions to either of the aforementioned documents and present any update 

or revision if a subsequent petition for extension or amendment occurs. Moreover, if 

any discrepancy exists between the exemption and procedures outlined in the flight 

manuals and/or general operating manuals, the conditions herein retain superiority 

and thereby must be followed. 

5. The crew for each commercial operation will consist of a pilot, spotter or visual 

observer, and camera operator. The spotter satisfies the visual line of sight 

requirement at all times so long as s/he is within the proximate verbal communication 

vicinity of the pilot. 

6. During all flights all persons not essential for flight operations will be considered nonpartied to the flight operations. Thus, the pilot will operate the sUAS the requisite 

distance from these non-parties to the flight operations in accordance with 14 CFR 

section 91.119. 

7. Before conducting commercial sUAS flight operations the crew will complete tests 

conducted by Center of the Universe Productions DBA COTU Media which will be 

documented as there are currently no established test standards for sUAS flight 

operations. The tests conducted by Center of the Universe Productions DBA COTU 

Media will coincide with the qualification processes detailed in the general operating 

manuals for the respective sUAS(s). The record completion of these processes will be 

documented and made available to the Administration upon request. 

8. The flight and general operating manuals will be available to the pilot at all times 

during flight operations in accordance with 14 CFR section 91.9 and 14 CFR section 

91.203. These documents will be made available to the Administrator or any law 

enforcement official upon request. 

9. Prior to conducting commercial aerial cinematography operations, the operator will 

log a minimum of 25 hours of total time as a UAS rotorcraft pilot in accordance with 14 

CFR section 61.51(b). Additionally, the operator will accumulate and log consistent 

with 14 CFR section 61.51(b) at least 5 hours of the make and model to be used for 

operations under the exemption with a minimum of six take offs and landings. 

10. During all training operations all persons not essential for flight operations are to be 

considered non-participants and the operator will be required to operate the sUAS in 

accordance with the distance requirements under 14 CFR section 91.119. 

11. Record of the successful completion of the qualification process detailed in the 

general operating manual and administered by Center of the Universe Productions DBA 

COTU Media will be made available for each member of the crew upon the request of 

the Administrator. As this is a requirement promulgated by Center of the Universe 

Productions DBA COTU Media the test is to be administered and implemented by a 

qualified person designated at the discretion of Center of the Universe Productions 

DBA COTU Media 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

12. Prior to commercial sUAS cinematography flight operations a demonstration will be 

administered by an operator approved and otherwise qualified and thereby 

documented. This documentation of the demonstration will be made available to the 

Administrator upon request. As no established tests or standards which support the 

jurisdictional FAA Flight Standards District Office evaluation with respect sUAS flight 

operations for the previously enumerated sUAS(s) Center of the Universe Productions 

DBA COTU Media will conduct these tests in accordance with the general operating 

manual. 

13. Any and all documents required under 14 CFR sections 91.9, and 91.203 will be 

available to the operator at any time during the operations of the aircraft. Moreover, 

these documents will be made available to the Administrator or and law enforcement 

official upon request. 

14. Under the event that the sUAS undergoes any maintenance, repair, or alteration which 

effects the flight operations, for example the replacement of a propeller, the entire 

sUAS will undergo a functional flight test. The flight test will be conducted in 

accordance with the general operating manual. The operator who conducts the results 

of the flight test in the sUAS aircraft records. 

15. Current maintenance procedures, inspection requirements, and lift limits for the 

entirety of the sUAS(s) enumerated herein will be periodically updated and retained 

on file with Center of the Universe Productions DBA COTU Media and made available 

to the Administrator upon request. 

16. Any technician who is to perform maintenance and/or inspection on the sUAS will 

meet all qualification criterions developed by Center of the Universe Productions DBA 

COTU Media with respect to the guidelines set forth in the general operating manual. 

Additionally, each sUAS operated under this exemption will comply with the 

manufacturer’s promulgated safety guidelines as the general operating manual 

provides processes by which to document and record the sUAS maintenance. 

17. Prior to each flight, the operator will inspect the sUAS to ensure it is safe for flight 

condition. The operator must approve of the aircraft in order for flight operations to 

ensue. If the operator finds upon the pre-flight inspection the sUAS ability to fly safely 

is compromised the aircraft is prohibited from operations until necessary maintenance 

has been performed and the sUAS is otherwise approved for safe flight operations. 

18. The sUAS will be operated in the visual line of sight of the operator, or the spotter 

under the instance that virtual reality eyewear is used by the operator so long as the 

spotter is within the proximate communication distance of the operator, at all times. 

19. All flights will be operated at an altitude of no more than 400 feet above ground level. 

All altitudes reported and recorded will be in feet above ground level. 

20. The operator will ensure no person(s) in open areas are allowed within 500 feet of the 

aircraft except under the circumstances that those persons by either express or 

implicit consent to be a party to the cinematography and are deemed necessary for 

the aerial cinematographic flight operations. However, if barriers exist between the 

sUAS operations and the non-parties to the flight operations which will sufficiently 

protect the non-parties to the flight operations from any debris in the event of a 

misfortunate event then the sUAS may operate closer than 500 feet to persons 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

afforded such protection. If a situation occurs to which the persons leave such 

protection of a barrier affording protection and are thereby within 500 feet, then the 

operator must either cease flight operations, or move to a safe distance of 500 feet 

away from said person immediately. 

21. The approval of Flight Standards District Office or aviation-safety inspector will be 

deemed unnecessary with respect to reductions to the distances set forth in the 

general operating manual consistent with the manned aircraft procedures promulgated 

in Federal Aviation Administration Order 8900.1, V3, C8, S1. However, the sUAS will 

always yield to the right of way to all other manned flight operations and aerial 

activities for example but not limited to parasailing, parachuting, and etcetera. 

22. The sUAS will not operate in a Class B, C, or D airspace without written approval from 

the FAA nor will the sUAS operate within five nautical miles of the epicenter of a nontowered airport unless otherwise a letter of agreement exists with the airport’s 

management. If such a letter manifests, it will be made available to the Administrator 

upon request. 

23. As per the general operating manual the sUAS will only operate within the secured 

area(s) which are established by pre-flight security perimeter(s) conducted and logged 

before each flight by the crew. A pre-flight briefing will establish the secure area, and 

security perimeter. Each member of the crew is required to attend this pre-flight 

briefing. The logs of the briefings and security perimeters will be made available to 

the Administrator upon request. 

24. Any accident will be reported to the National Transportation Safety Board per the 

instructions contained at www.ntsb.gov. In the event of an accident and after the 

report to the NTSB is submitted further flight operations for the sUAS and crew who 

were partied to the accident will be suspended until AFS-80 authorization to resume 

operations is provided. 

25. Applicant agrees that failure to comply with any of the conditions and limits of this 

grant of exemption are grounds for immediate rescission of this exemption. 

26. Unless otherwise specified in the grant of this exemption, applicant agrees to comply 

with all applicable parts of 14 CFR. 

Under 14 CFR part 11, the subsequent summary is provided for publication in the Federal 

Register: 

Center of the Universe Productions DBA COTU Media seeks an exemption from the 

following rules Title 14, Code of Federal Regulations (14CFR): §§ 61.113 (a) and (b); 

91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) & (b), and 

seeks permission to operate sUAS commercially in cinematographic flight operations. 

The approval of exemptions which allow commercial flight operations of sUAS(s) invariably 

enhance safety by reducing risks. Traditional aircraft can weigh in excess of 10,000 

pounds, use jet engines for propulsion, and at times operate in close proximity to people 

and fixed ground structures. Risks that are present in the traditional operations of manned 
235 E Broadway, Ste. 406, Long Beach, CA 90802 Phone 310-893-0856

aircraft include those associated with large amounts of highly flammable fuel and other 

flammable liquids. Dissimilarly, the sUAS weighing less than 55 pounds and operating on 

battery power eliminates the risks associated with manned aircraft as the lack of 

combustible fuel is ever present in sUAS flight operations. Moreover, sUAS(s) do not carry 

passengers or a crew and therefore do not expose people at large to the risks associated 

with manned aircraft. All flight operations will exist over controlled access properties with 

the prior consent of the property owner. All cinematographic flight operations will be 

conducted with the consent of the parties to the flight operations and all flight operations 

will be in compliance with local and state laws. 

The operation of sUAS in accordance with the conditions set forth hereinto provide an 

equivalent safety level which supports the grants of the exemptions petitioned for herein. 

The sUAS(s) Center of the Universe Productions DBA COTU Media seeks to use are small, 

lightweight aircraft, which operate in secure environments, close to the ground, at 

relatively slow speeds. All of which as a result suggests that Center of the Universe 

Productions DBA COTU Media ’s operation of sUAS(s) are safer to society than traditional 

operations conducted with helicopters or other aircraft. The criteria set forth in Section 

333 of the Reform Act have been satisfied by the applicant’s request. The enumerated 

conditional flight operations aforementioned do not create a hazard to users of the 

national airspace system and do not pose any national security threats or concerns. Thus, 

the foregoing meets the criteria necessary for granting the requested exemptions thereby 

allowing Center of the Universe Productions DBA COTU Media ’s commercial operations of 

sUAS pursuant to the general operating manual and the aircraft flight manuals attached 

hereinto. 

Respectfully Submitted with Kind Regards, 

______________________________________ 

Michael DeLano 

President

COTU Media

michael@cotupro.com