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

Docket 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 

333 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 hereby 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 Satellite 

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 summary 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 Aerial 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 substantial 

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 classic 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 forth 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 greater 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 control 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% remaining 

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\fENSIONS 

UNFOLDED 

Diameter - 1126 mm 

H eight (to base o f TITH) - 220 mm 

POWERPLANT 

N umber of Motors - 6 

Motor Type - Direct Drive 3 -Phase P MAC Outrunner 

Motor Model - F45 

Moto r Co ntinuo u s P ower Output - 350 W 

Moto r Instantaneous Peak P ower - 950 W 

E lectronic Speed Controller - Freefly Silent-Drive Sine Wave ESC 

PROPELLERS 

Mate rial - Carbon fibe r with balsa core 

Pro peller Orien tation - (3) CW and (3) CCW Props 

Pro peller Type - 18 x 6 F olding 

B ATTERY 

Nominal Batter y Voltage - 6S I 22.2V 

Maximum B attery S ize - 240 x 180 x 80 mm 

Maximum B attery Quantity - 2 B attery Packs (P a rallel) 

Batter y Connector s - 2x E C5 (Parallel) 

WEI G HTS 

Maximum Gross for Takeoff - 13.6 kg (30.0 lbs) 

Maximum U seful Load - 9. 1 kg (20.0 lbs) 

Maximum P ayload - 6.8 kg (1 5.0 lbs) 

Typical Standard Empty Weight - 4 .5 kg (10.0 lbs) 

SPECIFIC L OADINGS 

Typical S pec ific Power - 145 W /kg 

Thrust Rat io at Max T a keo ff Weight - 1.85 : 1 

FLIG HT C O N TROLLER 

Model Name - Freefly Synapse Flight Controller 

F light Modes - Manual 

Inputs 

H e ight H old 

P ositio n Mode 

Ret urn -To -H ome 

Auto -land 

S .Bus, S.Bus 2 , FPV S D Video 

Radios 

Futaba S .Bus & S .Bus 2 

Supported R a dio Controller Teleme try Sys tem s 

Futaba w / built-in voltage sense port 

F irst-P erson View Trans mitters 

F irst-P erson View OSD Telem e try 

User Configura ble 

Installed Transceivers- Wi-Fi 

Data L ogging Rate - 25 H z 

L I GHTING A N D I N DICATION 

Orientation Lights - 3 Watt RGB L EDs 

Orientation Light L ocation s - Outboard on B oom Ends 

Orientation Light Color - R e d , Ye llow, B l u e, G ree n , White 

Status Light - Rear-F acing R e d /White L E D 

Accessory Lighting P ort - 1 2 VD C 

Accessory Lighting P ort L ocation - Outboard o n B oom Ends 
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 operate 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 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 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 groundbased Operator. The risks associated with the use of UAS are lower than 

risks of commercial pilot operations contemplated by Part 61 allowing UAS 

use by a private pilot 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 operate 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 and 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, the 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 Certification 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 person 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 crew. 

The UAS at full capacity will not weight more than 55 pounds and does not have an onboard 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 interest: 

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 safety 

concerns when gathering footage from inaccessible 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 operations. 

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 aircraft 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 Alpha & 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 grant 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 by 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

poses no threat 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 national 

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