March

### 6, 2015



## ll»nz

# 1f!D(D)L$" 396 Washington Street Suite 260 Wellesley Hills, MA 02481-6209

U. S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe 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); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & 

### (b).

DearSiror Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, VizTools LLC, operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography forthe motion picture and television industry for scripted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by Section 333. 1

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspacethat is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancementsto the already safe operations in the film and television industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirementsfor the safe operation of such aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

The name and address ofthe applicant is:

VizTools LLC**Attn:Ro~ndJ.Bouche~J~** Ph: 781-789-9026 Email: rboucher@viztools.tv Address: 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

1 The conditions proposed bythe applicant are drawnfrom Order 8900.1 CHG 0, Volume 3, Chapter 8-lssue
a Certificate ofWaiverforMotion Picture and Television Filming. Page 1 VizTools LLC, 396 Washington Street, Suite 260, Wellesley Hills, MA02481- 6209

### March 6, 2015

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 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 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) 

### &(b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This lawdirects the Secretary of Transportation to considerwhethercertain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determinewhich types ofUASsdo not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following:
·_The UAS's size, weight, speed, and operational capability;
•_Operation ofthe UAS in close proximity to airports and populated areas; and
•_Operation ofthe UAS within visual line ofsight ofthe operator.

Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." /d. §333(c) (emphasis addedf
The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under§40101 ofthe Act,that includes sUASs, from the requirementthat all civil aircraft must have a current airworthiness certificate.

2 Applicant interprets this provision to placethe duty on the Administratorto not only process applications for exemptions undersection 333, butfor the Administrator to craft conditions for the safe operation ofthe UAS. ifitshould be determinedthatthe conditions setforth herein do notfulfill the statutory requirements for approval.



### Page2 VizTools llC, 396 Washington Street, Suite 260, Wellesley Hills, MA 02481-6209

### March 6, 2015

The Administrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section orany sections44702-44716 ofthis title ifthe Administratorfindsthe exemption in the public interest. 49 U.S.C. §44701

### (f) See a/so 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

VizTools LLC's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed ofno morethan 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line ofsight and will operate onlywithin the sterile area described in the VizTools Operations Manual, attached as Exhibit 1 (hereinafter "the Manual")3

. 

### Such operations will insure that the sUASwill "not create a hazard to users of the national airspace system orthe public."4



### Given the small size ofthe sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofUASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the cleardirection in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASsfor movie and television operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grant the requested exemption without delay.

AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY

The applicant proposes thatthe exemption requested herein applyto civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at leastan equivalent oreven higher level ofsafety to operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe movie and television filming operations conducted with conventional aircraft.

3Applicant submits this manual as a Confidential document under 14 CFR 11.35(b) as the entire manual contains proprietary information thatthe applicant has not andwill notsharewith others. The manual contains operating conditions and procedures that are notavailable to the public and are protectedfrom release underthe Freedom of InformationAct 5 USC 552 et.seq.

4 Reform ActSection 333 (b).



### Page3 VizTools LLC, 396Washington Street, Suite 260, Wellesley Hills, MA02481- 6209

### March 6, 2015

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

Page4 1. The sUASwill weigh less than 55 lbs. 2. Flights will be operated within line ofsight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 15 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 15 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feetAGL or, not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator. 6. sUAS pilot will be an FAA licensed airman with at least a private pilot's certificate and third class medical. 7. sUAS Pilot will be Pilot in Command (PIC). Ifa pilot certificate holderother than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated
as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. The Manual requires the establishment ofa "Security Perimeter" for the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations priorto each day's production activities. It will be mandatory that all personnel who will be performing dutieswithin the boundaries ofthe safety perimeter be presentfor this briefing. 10. The operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. 11. The operatorwill obtain the consent ofall persons involved in the filming and
ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required the Manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. 12. The operatorwill submit a written Plan ofActivities to the FSDO three days before the proposed shoot as required in the Manual. 13. Pilot and observerwill have been trained in operation ofsUAS generally and received up-to-date information on the particular sUAS to be operated as required by the Manual. 14. Observerand pilot will at all times be able to communicate by voice and/or text. 15. Written and/or oral permission from the relevant property holderswill be obtained. 16. All required permissions and permitswill be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter and land. 18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles oremergencies.

VizTools LLC, 396 Washington Street, Suite 260, Wellesley Hills, MA**02481~** 6209

### March 6, 

### 2015

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operation capability, and proximity to airports and populated area ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and underthe 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 sUAS to be operated hereunder is lessthan 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operation underthis exemptionwill be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is nowdonewith conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location of operation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. 

### § 45.23 (b). Making ofthe Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor mores than 6 inches high, the words "limited," :restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificates, an exemption may be needed asthe UASwill have no entrance to the cabin, cockpit orpilot station on which theword "Experimental" can be place. Given the size ofthe sUAV, two-ince letteringwill be impossible. The word "Experimental"will be placed on the fuselage in compliance with §45.29 (f).

PageS The equivalent level ofsafety will be provided by having the sUAV marked on its

VizTools LLC, 396Washington Street, Suite 260, Wellesley Hills, MA**024Sl~**-6209

### March 

### 6, 2015

fuselage as required by §45.29 (f) where the pilot, observerand others working with the sUAVwill see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptionsto this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) 

### & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections61.113 (a) 

### &(b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety of current operations by requiring the PIC

.operating the aircraftto have a private pilot's license ratherthan a commercial pilot's

license to operate this small UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is 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 as set forth in the Manual. The level ofsafety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associatedwith the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceedsthe present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

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 existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manualfor maintenance and use ofsafety check lists priorto each flight, as set forth in SectionsJ, Land Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Page6 Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof.

VizTools LLC, 396Washington Street, Suite 260, Wellesley Hills, MA02481-6209The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level ofsafetywill be maintained by keeping the flight manual at the ground control pointwhere the pilot flying the sUASwill have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737,8738,9299, 9299A,9565, 95658,10167, 10167A, 10602,32827, and 10700.

14 C.F.R. § 91.103: Preflightaction

This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manualswill not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafetywill be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data**b~fore** initiation offlight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 providesthat no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unlessthat aircraft has fully functioning dual controls.

sUASs and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicateswith the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controlsfor a numberofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neithera pilot nor passengerswill be carried in the aircraft and by the size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudesfor operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at lessthan the minimums prescribed, provided the person operating the helicoptercomplies with any route oraltitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, exceptforthe limited conditions stated in the Manual, the UASwill neveroperate at higherthan 400 AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operationswithouttheir pre-obtained consent.

Page 7 VizTools LLC, 396Washington Street, Suite 260, Wellesley Hills, MA02481- 6209

### March6, 2015

The equivalent level ofsafetywill be achieved given the size, weight, speed of the UAS aswell asthe location where it is operated. No flight will be taken without the permission ofthe property owneror local officials. Because ofthe advance notice to the property ownerand participants in the filming activity, all affected individualswill be
aware ofthe planned flight operations as setforth in the Manual. Compared to flight operationswith aircraft or rotorcraftweighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraftoperating at or below500 AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separation betweenthese smaii-UAS operations and the operations of conventional aircraftthat must comply with Section 91.119.

14 C.F.R. §91.121 AltimeterSettings

This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimeter setting available before departure."As the sUAS may not have a barometricaltimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecastweatherconditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least45 minutes."

The battery powering the sUAS provides approximately 15 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would not be possible. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight VFR conditions is reasonable.
Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofpriorexemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners orofficial representatives who have signed waiverswill be allowed, with lessthan 15 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, grounding sUAS flights which do not have sufficient reserves, would greatly reduce the utility forwhich the exemption will be granted.
Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 15 minutes or25% ofbattery powerwhichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

PageS VizTools llC, 396Washington Street, Suite 260, Wellesley Hills, MA 02481-6209March

### 6, 2015

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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 a civil aircraft unless it haswithin 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) ofthis 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 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS.

An equivalent level ofsafety 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 extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother 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 operatororowner "shall havethat aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...,u and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraftwith an airworthiness certificate, these sectionswill not apply to the applicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook as referenced in the Manuai.(See Sections Land Q) An equivalent level ofsafetywill be achieved becausethese small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL. As provided in the Manual, the operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Page 9 VizTools LLC, 396Washington Street, Suite 260, Wellesley-Hilis; MA 024Sl- 6209March

### 6, 2015

********* Pursuantto 14 C.F

### .R Part 11, thefollowing summary is provided forpublication 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 (551bs or less) in motion picture and television operations.
Approval ofexemptions allowing commercial operations ofsUASs in the film industrywill enhance safety by reducing risk. Conventional film operations, usingjet or piston power aircraft, operate at extremely lowaltitudesjustfeet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles thatweigh in the neighborhood of4,0001bs., carrying large amounts ofjetA orotherfuel (140 gallonsforjet helicopters shown below). Such aircraft mustfly to and from the film location. In contrast, a sUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the film setand not flown. The sUASwill carry no passengers orcrewand, therefore, will not exposethem to the risks associatedwith manned aircraftflights.

The operation ofsmall UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweightaircraft operate atslowspeeds, close to the ground, and in a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.
Privacy

All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Filming will be ofpeople who have also consented to being filmed orotherwise have agreed to be in the area where filming will take place.

All filming is to be conducted during daylight hours.

Page VizTools llC, 396Washington Street,Suite 260, Wellesley**Hill~,** MA 02481-6209 

# ·-

### March 6, 2015

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of

### 2012-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security- provide more than adequate justification forthe grantofthe requested exemptions allowing commercial operation of applicant's UAS in the motion pic;:ture and television industry pursuant to the Manual appended hereto.

Roland J. Boucher, Jr.

President VizTools LLC.



### Page VizTools llC, 396 Washington Street, Suite 260, Wellesley Hills,

# MA 02481- 6209