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Mr. Adam M Levins

Cell: +1.619.548.5151

adamlevins@gmail.com 

August 2, 2015 

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room 

w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11, Adam M Levins, (hereinafter petitioner or operator) of Small Unmanned Aircraft Systems 

(sUAS) equipped to conduct aerial data collection and motion picture and television industry 

for controlled and closed set filming, hereby applies for an exemption for the listed Federal 

Aviation Regulations to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of sUAS 

under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to 

access and 4) would provide safety enhancements to the already safe operations in the film and 

television industry presently using conventional aircraft. Approval of this exemption would 

thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “establish 

requirements for the safe operation of such aircraft systems in the NAS.” Section 333(c) of the 

Reform Act. 

THE NAME AND ADDRESS OF THE APPLICANT IS: 

Mr. Adam M Levins

Ph: 619.548.5151

Email: adamlevins@gmail.com

Address: 

2042 F Street 

Apt 1

San Diego

CA 92102
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AIRCRAFT REQUESTED FOR OPERATION: 

• Cinestar 6 

• Cinestar 8 

• Cinestar 8 Okto XL 

• DJI Flame Wheel F450

• DJI Flame Wheel F550

• DJI Inspire 1

• DJI Inspire 2

• DJI Phantom 2 Vision+

• DJI Phantom 3

• DJI Spreading Wings S1000+

• DJI Spreading Wings S1000

• DJI Spreading Wings S900

• 3D Robotics Solo 

• FreeFly Systems ALTA

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED: 

14 C.F.R. 45.23(b), 14 CFR 61.113(a) and (b), 14 C.F.R. 91.7(a), 14 CFR 91.9(b)(2), 14 C.F.R. 

91.103, 14 C.F. R. 91.119, 14 C.F.R. 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 407(a)

(1), 14 CFR 409(a)(2), 14 CFR 417(a) and (b) 

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 rulemaking 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. 
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Adam M Levins’s UASs are rotorcraft, weighting 55 or fewer lbs. including payload. They 

operate, under normal conditions at a speed of no more than 87 knots and have the capability 

to hover, and move in the vertical and horizontal plane simultaneously. Such operations will 

insure that the UAS will “not create a hazard to users of the national airspace system or the 

public.” 

PUBLIC INTEREST STATEMENT 

Given the small size of the UASs involved and the restricted sterile 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 television 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. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant 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 represent a safety enhancement to the already safe 

movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions to which Adam M Levins agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. Operations authorized by this grant of exemption are limited to the aircraft requested in 

the “AIRCRAFT REQUESTED FOR OPERATION” section of this petition when weighing 

less than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 
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airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times; electronic messaging or texting 

is not permitted during flight operations. The PIC must be designated before the flight 

and cannot transfer his or her designation for the duration of the flight. The PIC must 

ensure that the VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Conditions and Limitations in this grant of exemption, Adam M Levins is hereafter 

referred to as the operator. Administrator upon request. If a discrepancy exists between 

the conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. It is 

the operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 
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least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 

61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC’s ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under this 

exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 
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15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter 

of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N

−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC 

at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 
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24. The UA must remain clear and give way to all manned aviation operations and activities 

at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that 

sufficiently protect nonparticipating persons from the UA and/or debris in the event of 

an accident. The operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations must cease immediately in a manner 

ensuring the safety of nonparticipating persons; and b. The owner/controller of any 

vessels, vehicles or structures has granted permission for operating closer to those 

objects and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard. The PIC, VO, 

operator trainees or essential persons are not considered nonparticipating persons 

under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may 

be waived with the concurrence of the FSDO. The plan of activities must include at least 

the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted under 

this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 
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f. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave 

permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

14 C.F.R. 45.23(b): Aircraft Marking 

All Adam M Levins aircraft, for the use of production, shall be marked with a serial number and 

company identification. Labels will be a height of one inch. (ie: AL1001).

14 C.F.R. 61.113(a) and (b): Sport Pilot Privileges and Limitations: Pilot in Command.

Adam M Levins observes previous exemptions to a minimum of sport pilot certificate and 

therefore requests the same exemption. 

14 C.F.R. 91.7(a): Civil aircraft airworthiness.

Adam M Levins shall only fly aircraft as determined in “Airworthy” condition. 

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

Adam M Levins shall have, at the ground station documents required under 14 CFR §§ 91.9 

and 91.203 available to the PIC at the Ground Control Station of the UAS any time the aircraft 

is operating. 

14 C.F.R. 91.103: Preflight Action.

The PIC will complete a preflight inspection prior to each flight. 

14 C.F.R. 91.119: Minimum Safe Altitudes.

Adam M Levins will comply at all times the requirement to fly 400 feet AGL and bellow. We 

observe the exemption provided and granted by other applicants. 

14 C.F.R. 91.121: Altimeter Setting.
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Prior to motor start, the PIC shall accomplish a Flight Control/Navi/GPS calibration that sets the 

GPS “Home” location, zero altitude, and heading. As observed in previously granted 

exemptions, this complies. 

14 C.F.R. 91.151 (a): Fuel Requirements for Flight in VFR Conditions.

Adam M Levins will limit flights to 30 minutes or 25% remaining battery power, whichever 

happens first. We observe the exemption provided and granted by other applicants. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) and (b): Maintenance Inspections 

Adam M Levins will comply with the recommended maintenance program as put forward by 

the manufacturer of each aircraft approved under this exemption. All maintenance actions and 

will be recorded in the aircraft maintenance log. All maintenance personnel shall follow UAS 

guidance. We observe the exemption provided and granted by other applicants. 

Adam M Levins will comply with all current and future directives provided by the FAA with 

regard to UAS operations. 

Respectfully submitted, 

/s/ 

Adam M Levins

2042 F Street

Apt 1 

San Diego

CA 92102 

Tel: 619.548.5151 

Email: adamlevins@gmail.com