### July 27 2015 U.S. Department ofTransportation-. DocketManagement System 1200NewJerseyAve., SE , . Washington, DC20590 To whom itmay concern: Submitted andrelated to: ',/.



### 01) Exemption Request- Section 333 oftheFAAReformAct
Pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 (the ReformAct) and 14 C.F.R. Part 11, GreenMoss Grows Media, LLC, doing business as andpubliclybranded as UC OREGON TV, an operator ofSmall UnmannedAircraft Systems (UAS orUAVs) equippedto conduct aerial 

### ' photographyfor the motionpicture andtelevision and contentproduction, creation industry for scripted closed set filming, hereby applies for an exemption from the listed FederalAviation Regulations (FARs) to allow commercial operation ofits UAS, so long as such operations are conducted within and underthe conditions outlinedherein or as maybe establishedbythe FAA as required by Section 333.1 or other pertinent sections as appliedbyfederal law. As described more fully below, the requested exemption wouldpermitthe operation ofsmall, unmanned and relatively inexpensive UAS under controlled conditions inairspace that is 1) limited 2) predetermined 3) controlled asto access and 4) wouldprovide safety enhancementsto the already safe operations inthe film and television**indu~try** 

### presentlyusing conventional aircraft. Approval ofthis exemptionwould thereby enhance safety and;fulfill the Secretary ofTransportation's (the FAAAdministrator) responsibilities to establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system. Section 333(c) oftheReformAct. The name and address ofthe applicant is: EddieV Garcia, CEO Green Moss Grows Media, LLC, d/b/aUC OREGONTV 1904AdamsAvenue La Grande, OR97850 (541) 316-5650 ucoregontv@gmail.com

December 1, 2014 Green Moss Grows MediaLLC FAASection 333 ExemptionApplication Page 1of9U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act 

### To whom.it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Green Moss Grows Media, LLC, doing business as UC OREGON TV, operator ofSmall Unmanned Aircraft Systems (" UAS") equipped to conduct aerial photography forthe motion picture and television and content creation industryfor scripted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow/commercial operation of its UAS, 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 permitthe operation ofsmall, unmanned and relatively inexpensive UAS 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 ofthis exemption would**there~y** enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

The name and address ofthe**applican~** 

### is:

. 

### EddieV Garcia, CEO Green Moss Grows Media, LLC, dbaUC OREG()NTV 1904AdamsAvenue · · La Grande, OR97850 (541) 316-5650 ucoregontv@gmail.com

1The conditions proposed by the applicant are drawn from Order 8900:1 CHG 0, Volume 3, Chapter 8-lssue a Certificate ofWaiverfor Motion Picture and Television Filming and parts thereof.

Green Moss Grows MediaLLC FAA Section 333 ExemptionApplication '· 

### .. •

Page 2 of9

# FAA UAS Exemption RequestApplication

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333{a) through

_ (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rule-making·required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users ofthe (NAS) orthe public or pose athreatto national security in light of the following: i. The UAS's size, weight, speed, and operational capability; 

### li. Operation of the UAS in close proximity to Airports, Heliports, Power Plants, Fuel Depots and populated areas; and li. Operation cif the UAS within visual line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles 

### umayoperate safely in the national airspace system (NAS), the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." 

### ld. §333(c) (emphasis added). The Federal Aviation Act

### ex~re~sly grants the FAA the authorityto issue

### exe~ptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, which includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

. Applicant hereby interprets this provision to place the duty on the Administratorto not only process applications forexemptions under section 333, butforthe Administratorto craft conditions for·the sa'fe operation of the UAS, if itshould be determined thatthe conditions set forth herein do notfulfill the statutory requirements for approval. The Administrator may grant an exemption from

# a**r~quirementof~** regulation 'prescribed undersubsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 

## usc §44711(a); 49 

## usc §44704; 14 CFR §91.203 

### (a) (1). Green Moss Grows Media LLC's UAS are multi rotor craft, weighting 55 orfewer lbs. inCluding its payload. They operate, under normal conditions at a speed of no more than 50 mph 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 only within the sterile area described in the GMGM LLC Operating Manual, (hereinafter 11GMGMGOM"). Such operations will insure that the UAS will 11not create a hazard to users ofthe national airspace system orthe public."

.. Given the small size ofthe UAS 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 of UAS to commence immediately. Also due to the size ofthe UAS and the restricted areas in which the relevant UAS will operate, approval ofthe application presents no national security issue. Given the clear direction 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 UAS for 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.

Green Moss Grows MediaLLC FAASection 333 ExemptionApplication Page 3 of9

## FAA UAS Exemption ReguestApplication
AIRCRAFT AND EQUIVALENT L.EVEL OF SAFETY 

### The applicant proposes that the exemption requested herein apply to civiiaircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations underthe 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 Green Moss Grows Media, LLC agrees to be bound when conducting commercial operations under an FM issued exemption include; Green Moss Grows Media LLC will utilize a Phantom 2.Vision UAS and reserve the opportunityto contract a licensed UAS operator, pursuant to FAA.rules arid its own COA certificate to shoot production shots forthe exclusive use of Green Moss Grows Media, LLC. Our Phantom 2Vision is compliant as follows:
1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within .lineofsight ofa pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should.that occur priorto the 30 minute limit. 4. Flights will be operated at an altitude of no more than 200 feetAGL or, not more than 200 feet above an elevated platform fromwhich filming is planned. STRICTLY ENFORCED. 5. Minimum crewfor each operation willconsist oftheUAS Pi!ot, the Visual Observer. 6. UAS pilot will operate undt;!r the**guid~nce** 

### and o:versight of an FM licensed airman with at least a private pilot's certificate and third class meqicaL 7. UAS Pilot will be Pilot in Command (PIC}. Ifa pilot certificate ho.lder otherthan the UAS Pilot, who po$sess the necessary PICqualifications, is also present onset (i..e. the Aerial Coordinator), that person can also be designated as PIC. 8. The UAS will only operate within a confined."Area of;Operation"**asd~fined** 

### inthe law. 9. A briefing will be conducted in regard tothe planned UAS operations prior to each day's production.activities

.. lt will be mandatory that all personnel who will be performing duties within the boundaries ofthe area ofoperations be present forthis briefing. 10.The operator will file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office (FSDO) as required under law. All filings shall be kept in afile for (2) two years and for inspection. 11. The operatorwill obtain the consent ofall persons involved in the filming.and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety as described in the operations. With the advanced permission oftherelevant FSDO, operations at closer range can be approved. 12.The operator will submit a written Plan ofActivities to the FSDO (5) FIVE days**b~fore** 

### the**p~oposed** 

### shoot as required. 13.All Green MossGrows Media LLC crew will**hav~~:** 

### been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required. 14. Observer and pilot will at all times _be able to communicate by voice, Motorola closed circuit**in~ear** 

### handheld devices. 15. Written and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtajned from territorial, state, countyor cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies if necessary and required under commensurate law(s).

Green Moss Grows MediaLLC FAA Section 333 ExemptionApplication Page4 of9

## ·. FAA UAS Exemption Re-questAgplication
17. If the UAS 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 UAS will have the;capability to abort a flight in case .of unpredi.cted obstacles or emergencies or change in weather·or other altering effe.ct that endangers the productionor public.
14C.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 of airworthiness certificates as required by FAR §91.203 (a) (1}. Given the size and limited operating area associated with the aircraftto' be utilized by theApplicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofth.e'Reform Act. The Federal Aviatio

..n Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports, power plants, fuel depots and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft} operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no.explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the General Operating Manual. Unlike other civil aircraft, operations u'nder this exemption will be tightly controlled and monitored by both the operator, pursuantto the Manua'l's requirements, and'underthe requirements and in compliance with local public safety requiremehts, to provide·securityforthe-area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements;·which already apply to'civil aircraft operated in connectio-n 

### W'ith motion pictute and television production, provii:le a greater degree ofsafetytothe ifublic and property owners than conventional operations conducted with airworthiness certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible ttireat to national security posed 

### by the UAS, due to hs :size, speed ofoperation, locc:.tion ofoperation, !ack of explosive materials orflammable tiquid fuels, and inabilityto carry asubstantial external load.·
14 C.F.R. § 

### 45.23 (b). Marking ofthe Aircraft the 'regulation requires: When marks include only the Roman capitallette'r "N"·and the registration nurnber is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operatormust also displayon that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional;" as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be heeded as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAV; two-inch lettering will be impossibre. The woi'd"Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the UAV marked on its fuselage as required 

### by §45.29 (f) where the pilot,observer and others working with the UAV will see the identifiCation ofthe UAS as "Experimental." The FAA has issued the following exemptionsto this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. Green Moss Grows MediaLLC FAASection 333 ExemptionApplication Page 5 of9

## FAA UAS Exemption RequestApplication
14C.F.R. § 61.113 (a) 

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

.. Sections

# 61.11~ (a):& 

### .(b) limit

# p'riv~t~**pii~t~::to-;non~coi1lme,rctai_o.perations. Bec~~s~--~he** **i.JA~wiil n·~t** **~arry** a pilot or passengers, the proposed operations can achieve ttie equ'ivalent level ofsafety ofcurrent operations by requiring the PIC opera.ting the aircraftto ope**rat~** underthe supervision ofa private pilot's license h()lderrather than a commercial pilot's license holder. Unlike a

### conven~iqnalaircraft thatcarries the pilot and passenger,s, the ·UAS is

. remotely controlled with no livingthing on

### board~_ The areaofoperation iscontrolled and restricted,and all flights are planned and coordinated in advance as set forth in the GOM. The level ofsafety provided bythe requirements included in the GOM exceed that provided by a**singl~** individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe UAS as requested with a private pilot in a supervisory role aiding the PIC exceeds the present level ofsafety 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 forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Giventhe size ofthe aircraft and the requirements contained in the General Operating Manual for maintenance and us,e ofsafety check lists priorto each flight, an equivalent level of
- safety will be provided.
14C.F.R. § 91.9 (b) (2):.Civil Aircraft Flight**M~:mual** inthe Alrc:raft. Section 91.9 (b) (2) provides: No person may operate a u.s.-registered civil-aircraft

... . ' (2) For which 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, or any combination thereof. · The UAS, given its size and configuration has no ability or place to carry such aflight 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 ofsafety will be maintained by keeping the flight manual at the ground control point where the pilotflying the UAS will have immediate access to it. The FAA has issued the following exemptions tothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, an(,i107!)0.
14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in comrn2r.d to_take certainactions before flight,to insurethe safety of flight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption wili be needed. An equivalent level ofsafety 

### vyil,l be provided as setJQrthinthe_Aircraft Operating Manual**(~OM)** for each _UAS. The PIC will take all actions'as descr'ibed in the GOM and AOM. '

. ' ' '

. . . ".

Green Moss Grows MediaLLC FAASection 333 ExemptionApplication Page 6 of9

## FAA UAS Exemption RequestApplication
14C.F.R. §91.109: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instrudion unless''th:at ()ird"aft has fully'functioning dual controis.

· UAS and remotely piloted·airi::raft, 

# bv their deslghdo nofhavefulh/

### fu~<:ti~:nal dual.i::ol'ltrols: Flight control is· accomplished through the use ofa control box thatcommunicates with the aircraft via radio communications. The FAA has approved exemptions for flight training withoutfully funCtional dual controls for a numberofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K 

### & 9862A. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried inthe aircraft and by the size and speed ofthe aircraft. 14C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 Above Ground Level (AGL,) or not more than 200 above an elevated platform from which filmin'g is planned, ari exemption may 

### be needed to allow such operations. However,·Green Moss Grows Media LLC will ONLY fly below 200 feet at all times. As set forth herein, except for the limited conditions stated in the General Operating**Manual~** 

### the UAS will neveroperate at higher than 400 AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained notification and consent when required. · The equivalent level ofsafety will be achievedgiven the

### ~ize, weight, speed'c:ifthe

### UASakw~ll-asthe locat-ion where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations as set forth in the GOM, Compared to flight operations with aircraft or rotorcraftweighing 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 aircraft operating at or below 500 AGL in the movie industrlln addition, the

### lo\N'~altitude operations ofthe UAS will ensure separation between these smaii-UAS operations and'the operations o'fcoriventional aircraft that must comply with Section 91.119. 14c.F.R. §91.121 Altimeter

### s~ttings This regulationrequires each person operating an·aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...tothe elevation ofthe departun{airportor an appropriate altimeter setting available before departure:' As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant tothe General Operating 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 Requirements for Flight inVFR Conditions

: ' !**~**



### ... Section 91.151 (a) proh'ibits an individu.al from

### beginriih~**~~~flight** inan airp_lane un·9er VFR.conct'itions uni!=!SS (considering wind and forecast weather conditions) there is enough fuel to fly to the 'flrst point 

### 6f intended landing; and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

Green Moss Grows MediaLLC FAASection 333 ExemptionApplication Page 7 of9

## FAA UAS Exemption RequestApplication
Green Moss Grows Media LLC requests relieffrom_Section 91.151 due to the battery life that powersthe UAS. Typical aerial batteries provide approximately40· minutes ofpowered flight. To meetthe 30-minute reserve requirement in 14 CFR §91..151, UAS flights would be limited to approximately 10 minutes in length: ln·reliefofthe 30-minute reserve, given the limitations on the WAS's proposed area ofpredetermined operation, a longertime frameforflight might be reasonable. As per our internal rules, Operating Manual, flight times will never exceed 75% ofthe battery(s) consumption or 25% reserve; whichever happens first. We will also secure 

### a 2nd battery for unit. Applicant believes that an exemption from 14CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% of battery powerwhichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673,·and 10808. 

### 14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft

### Certification and Registration The regulation provides in pertinent pa;rt:.;

. (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

... 

### (a) 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 atthe cabin or cockpit entrance so · that it is legible to passengers or crew. The UAS fully loaded weighs no morethan 55 lbs and is operated without an on-board pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. Each UAS operated by Green Moss GrowsMedia, LLCwill be registered with the FAA and all documentation carried by the PIC.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilotflying the UAS will have immediate access to them, to the extentthey are applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816Ai and 10700. 

### 14C.F.R. §91.405 {a); 407 (a) (1}; 409 (a) (2};417(a) & 

### (b): Maintenance Inspections
These regulations require that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...:' and others shall inspect or maintain the aircraft in compliance with Part 43.
Green Moss Grows MediaLLC FAA Section 333 ExemptionApplication Page 8 of9

# FAA UAS Exemption RequestApplication
Given thatthese sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to. the applicant. Maintenance wilt be accomplished 

### by the operator pursuantto the guidelines set forth in the Maintenance manuals designed for each UAS. An equivalent level ofsafety will be. achieved because these small UASs are very limited in size and will carry a small payload and operate onlyin restricted' areas forlimited · periods oftime. Ifmechanical issues arise the UAS can land immediately and will·be operating from no higher.than 400 feetAGL. As provided in the GOM, the operatorwill ensure thatthe UAS·is in working.order,priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. Pursuant to 14 C.F.R. Part 

### 11, the following summary is provided for publication 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 of UAS in the film and content creation i'hdustry will enhance safety by reducing risk. Conventional film operations, usingjet or piston power aircraft, operate at extremely low altitudesjustfeetfrom the subject being_filmed and in extreme proximityto people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,0001bs., carrying large amounts of jetA orotherfuel (140 gallons forjethelicopters, e.g;). Such aircraft:must fly to and from the film location. In contrast, a UAS weighing fewerthan 55 lbs. and powered by batteries eliminatesvirtually all ofthat risk given the reduced ruass and lack ofcombustible fuel carried on board. The UAS is carried to the film set and notflown. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights

.. The operation ofsmall UASs, weighing less than 55 lbs., conducted inthe strict conditions outlined above, will provide an equivalent level of safety supportingthe grant ofthe exemptions requested herein, including exempting the applicant fromthe requirements ofPart 

### 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, closetothe ground, and in asterile environmentand, as 

### a result; are far saferthan conventional operations conducted with turbine helicopters operating in close proximitytothe ground and people. Privacy

·,,. ·: All flightswill occur over private or controlled access propertywith the property owner's prior consent and knowledge. Filming will be of people who have also consented to being filmed orotherwise have agreed to be in the area where filming will take place. Satisfaction ofthe criteria provided in Sectior. 333 ofthe Reform Act of2012.--size, weight, speed, operating capabilities, proximityto airports and populated areas and ojJeration within visual line ofsight and national securityprovide more than adequate justification forthe grant ofthe requested exemptions allowing commercial operation of applicant's UAS in the motion picture and television industry pursuant

### tothe Manual appended hereto. Thank you,

Eddie V Garcia Green Moss Grows MediaLLC FAA Section 333 ExemptionApplication Page 9 of9