### Alpha & Omega Entertainment C/O Branden Morris

- Owner 24451 Mira vista St.

Valencia, CA 91355

(310) 775

- 2371 bmorris@ao

- ent.com 

# November 21st , 2015 U.S. Department of Transportation Dock et Operations 1200 New Jersey Ave., SE Washington, DC 20590 RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code of Federal Regulations Pursuant to Section 33 3 of the FAA Modernization and Reform Act of 1012 (Public Law 112 - 95) Regarding Commercial Employment of Unmanned Aircraft Systems (UAS) Dear Sir/Madam,
Pursuant to Section 333 of Public Law 112

- 95 commonly known as the “FAA Modernization and Reform Act of 2012” or “The Reform Act”, Alpha and Omega Entertainment he reby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations within the United States National Airspace System (NAS) for the purpose of Closed Set Motion Picture, Television, and Commercial Production. Newsgathering and Sat ellite Media Tour events. It is the request of Alpha & Omega Entertainment to legally and safely operate the Freefly Alta (Serial Number 144711) UAS in the National Airspace System. Federal Register Summary Pursuant to 14 CFR §11.81, the following summa ry is provided for publication in the Federal Register, should it be determined that publication is needed: Alpha & Omega Entertainment seeks exemption from 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR 61.113(a)(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR

# 91.151(a); 14 CFR 91.203(a)(b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); CFR 91.409(a)(1) and (a)(2); 14 CFR 91.417(a)(b) to allow commercial employment of Unmanned A erial Systems (UAS) for the purpose of Closed Set Motion Picture, Television, and Commercial Production. Newsgathering and Satellite Media Tour Events. This exemption will enhance safety by reducing risk to the general public and property owners from the s ubstantial hazards associated with performing equivalent work with conventional aircraft and rotorcraft. Alpha & Omega Entertainment is a leading boutique production company based in Southern California specializing in leading edge cinematography and cla ssic storytelling. As you will read below our operations under the exemption will adhere to the strict operating requirements and conditions to ensure the equivalent standard of safety expected by those using manned aircraft and under the conditions set f orth by the FAA as required by Section 333. It is our feeling that operating the Freefly Alta UAS will be safer and more cost effective than our previously employed manned helicopter aerial filming. We have confidence that our operations will achieve a gr eater level of safety providing our pilots with air to ground communications and a Stratus 2S GPS locating device to ensure our UAS will be visible on the upcoming mandatory locating devices for all aerial flights. We will also be in contact with local con trol towers prior to flights to inform them of our flight plans. We will monitor and state our positions over the air in local air frequency for other pilot’s safety.
With over a thousand of flight hours logged by our two main pilots through their private pilot licenses, and flight instructor license we have extensive knowledge in FAA regulations and communication instructions. Our medical certificates our current and one will always be the PIC for every flight. The Freefly Alta will be controlled by the Futaba 14SG using 2 redundant receivers to always provide a back up radio signal. Live telemetry readings will be provided on the FPV camera and audibly through the Futaba controller. All flights will terminate when the flight batteries reach 25% remaini ng capacity. This will always ensure a safe flight return to the designated landing and takeoff area. In the highly unlikely event of the Alta loosing signal it will automatically initiate the return home function and will climb to a safe altitude and then land at the previously appointed landing area.

# Freefly Alta Specifications

DL\fE NS IO NS
UN FOLDED Diameter

- 1126 mm H eight ( to ba se o f TITH )

- 22 0 mm
POWERP L ANT N umber of Mo to r s
- 6 Mot or Type

- Dir ect Dri ve 3

- Pha se P MAC Outrunner Mot or Model

- F45 Mot o r C o ntinu o u s P ower Outpu t

- 350 W Mot o r In st antaneou s Peak P owe r
- 950 W E lectronic Speed Controller

- Freefl y Silent

- Dri ve Sine Wave ES C
PR OP ELLER S Mat e ria l

- Carbon fib e r with ba l sa co re Pr o peller Or ie n tatio n
- (3) CW and (3 ) CCW Pr ops Pr o peller Type

- 1 8 x 6 F olding
B AT TERY No minal Bat te r y Voltage

- 6S I 22

. 2V Maximum B attery S iz e
- 240 x 1 80 x 80 mm Maximum B attery Quanti ty

- 2 B attery Pack s ( P a rall el) Bat te r y Conne cto r s
- 2x E C5 ( Paralle l)
WE I G HT S Max i mum Gross for T akeo ff

- 13.6 kg ( 30.0 lbs ) Max i mum U se ful L oa d

- 9. 1 kg ( 20.0 lb s) Max i mum P ayload

- 6.8 kg (1 5. 0 lb s) Typica l Standard Empt y We i ght

- 4

. 5 kg ( 10

. 0 lbs )
SPEC IFI C L OADI NGS Typical S pe c ifi c Power

- 145 W / kg Thru s t Ra t io at Max T a ke o ff We i ght

- 1. 85 : 1
FLI G HT C O N TROLLER Model Na me
- Fr eefly Synapse Flight Controlle r F l i ght Modes

- Manua l

Input s H e i ght H old P osi ti o n Mode Re t urn
- T o
- H ome Aut o
- land
S

. Bu s , S. Bu s 2 , FP V S D V id eo Radios Fu ta ba S

. Bu s & S .Bu s 2 Supported R a dio Controller Telem e tr y Sy s te m s Fu ta ba w / built

- in vo ltag e se nse por t F i r st

- P erson View Tran s mitters F i r st

- P erson Vi ew OS D T ele m e tr y Use r Con figur a bl e In stalled Tran sceivers

- Wi

- Fi Data L oggi ng Ra te

- 25 H z L I GH TI NG A N D I N DI CA TIO N Orien tatio n Ligh ts

- 3 Watt RGB L ED s Orien tatio n Light L ocat i o n s
- Outb oa rd o n B oo m End s Orientation Light Co lor

- R e d , Y e ll ow, B l u e, G re e n , White Sta tu s Light

- Rear

- F ac in g R e d /W hi te L E D Accessory Li ghting P o rt

- 1 2 V D C Accessory Li ghting P o rt L ocatio n
- Outb oar d o n B oo m End s

# The altitude can be limited by the onboard flight control system. The UAS weighs less than 55 pounds, even with the camera system loaded with the full payload. We will not oper ate at speeds of more than 87 knots. The UAS can hover, and can simultaneously move vertically and horizontally . We will only operate in line of sight of the operator (PIC). The PIC will check for any Temporary Flight Restrictions (TFR) by visiting the FAA website and by using the Fore Flight App. We will not violate National Airspace System (NAS). Our aircraft management software will be able to track all of the components of the UAS as well as the flight time for the UAS and pilot. A stringent flight log record will be kept for the UAS and the PIC.
SPECIFIC EXEMPTIONS REQUESTED DESCRIPTIONS

14 C.F.R. **§** 61.113{a) and (b): Private Pilot Privileges and limitations: Pilot in Command 

## Sections 61.113 (a) 

# and {b) limit private pilots to non

- commercial operati ons. 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 a private pilot's license rather than a commercial pilot 's license to operate a small UAS. 

# The operational area will be controlled, and will not be covering large amounts of area. The UAS is remotely operated and controlled by a ground

based Operator. The risks associated with the use of UAS are lower than ri sks of commercial pilot operations contemplated by Part 61 al lowing UAS use by a private pilo t as the PIC exceeds the present levels of safety sought by 14 C.F.R § 61.113{a) and (b)

. 14 C.F.R. § 

## 91.7 (a) Civil aircraft airworthiness (a) No person 

# may ope rate a civil aircraft unless it is in an airworthy condition. 

# No FAA regulation standard exists for airworthiness of the UAS, so we request an exemption. Alpha & Omega Entertainment will operate in conjunction with all stated product document warnings an d safety operations to determine airworthiness before each flight. 4 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes 

## for operation 

## of civil aircraft. 

# Section 91.119 provides, in 

# pertinent part, that:

"

... 

# except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: ..... (b) 

# Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In 

# those cases, th e aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure."

# Because we are only allowed to operate up to 400 AGL, an exemption is needed to allow operation. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Ce rtification and Registration The regulation provides in pertinent part: (a) 

# Except as provided in§ 91.715, no person may operate o civil aircraft unless it has within it the following: {1} 

# on appropriate and current airworthiness certificate. {b) No 

# per son may operate o 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 cre w. The UAS at full capacity will not weight more than 55 pounds and does not have an on

board pilot. There is no area to display or carry the aircraft certification and registration on the UAS. All documentation will be available for viewing by the PIC on the ground.

WHY GRANTING THIS PETITION FOR EXEMPTION IS IN THE PUBLIC INTEREST As introduced above, the requested exemption would authorize the Applicant to perform commercial operations with UAS that will provide significant benefits to the public i nterest: 1 The use of UAS will decrease congestion in the National Airspace System along with reducing the noise and air pollution generated during traditional manned aircraft flight operations. 2 When using UAS to complement ground filming , they reduce safe ty c oncerns when gathering footage from inacce ssible or unstable/unsafe areas. 3 Operation of UAS will substantially reduce the risk to life and property in the air, and on the ground, which is commonly associated with traditional manned aircraft flight oper ations. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircr aft systems in the national airspace system."

ADDITIONAL NOTES Privacy

- All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Operations will be where the owners have agreed to all of Alp ha & Omega Entertainment activities to take place. In addition, members of the general public will be alerted to the operation of the UAS at these locations.

# In filing this application, Alpha & Omega Entertainment also requests that the FAA combine the g rant of the Section 333 exemption with a stand

- alone Certificate of Operation (“COA”) that will allow commercial operations of the Freefly Alta without filing for a COA for each flight. Compliance with the conditions agreed herein and that may be imposed b y the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from other aircraft. Notice to airmen and notice to air traffic control can be provided by the filing of a NOTAM as set forth within the proposed conditions. NATIONAL SECURITY Grant of this exemption will not raise any national security concerns. Given the size, load carrying capacity, speed at which they operate and the fact that it carries no explosives or any other dangerous materials, the Freefly Alta pose s no threa t to national security. IN CLOSING Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and nation al security

- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicants UAVs for the purposes outlined herein and are consistent with exemptions already granted, including Exemptions 11062 through 11067, 11080, 11109 through 11112, 11114, 11136, 11138, 11150 and 11153. Given that Alpha & Omega Entertainment is willing to abide by conditions the FAA has required in issuing recent Section 333 exemptions, the FAA has a strong basis for prompt consideration and grant of this request.

Sincerely, Branden Morris

Owner/Pilot Alpha & Omega Entertainment