Jeff	Aiello

18THIRTY	Entertainment

1703	N.	Carolina

Clovis,	CA	93619

Tel:	559-353-4085

Email:	jeffaiello1830@gmail.com

December	28,	2015

U.S.	Department	of	Transportation	Docket	Management	System																																							

West	Building	Ground	Floor 																																																																																																		

Room	w12-140	1200	New	Jersey	Avenue,	SE																																																											

Washington	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam:

We	respectfully	request	exemption	under	Section	333	of	the	FAA	Reform	ACT	and	Part	

11	of	the	Federal	Aviation	Regulations.	

Petitioner:

Jeff	Aiello	Owner/Executive	Producer																																																																												

18THIRTY	Entertainment																																																																																																										

1703	N.	Carolina	Clovis,	CA	93619																																																																															

Telephone:	559-353-4085																																																																																																						

Email:	jeffaiello1830@gmail.com

18THIRTY	Entertainment is	a	California	LLC	business.	18THIRTY	Entertainment intends	to	

use	a	UAS	for	the	purposes	of	commercial	photography/videography in	the	production	

of	television	commercials	and	long-form	productions.

Proposed	Operations

18THIRTY	Entertainment proposes	to	use	the	following platforms	in	seeking	a	Section	

333	exemption:	DJI	Phantom	2	&	3	and	3DR	SOLO.
Public	Benefit

18THIRTY	Entertainment produces	television	commercials	and	programs	that	regularly	

use	aerial	photography	to	enhance	the	educational	and	entertainment	quality	of	the	

product.	Using	a	UAS	in	lieu	of	a	manned-platform	such	as	a	rotary-winged	aircraft	is	

safer	with	regards	to	not	requiring	a	pilot	and	is	less	of	an	impact	on	places	close	to	such	

filming	with	regards	to	the	public.	

Reasons	why	the	exemption	would	not	adversely	affect	safety	or	how	the	exemption	

would	provide	a	level	of	safety	at	least	equal	to	the	existing	rules:

1. The	UAS	platforms	proposed	weigh	less	than	20	pounds	including	payload.

2. Flights	will	be	operated	in	VFR	conditions	and	in	visual	LOS	of	the	pilot.

3. Flight	times	are	typically	under	10	minutes	each.

4. Flights	are	typically	operated	under	200	feet	AGL.

5. Minimal	crew	will	consist	of	a	UAS	pilot	and	a	visual	observer.

6. A	pre-flight	briefing	will	be	conducted	before	each	flight	with	crew.

7. Written	and/or	oral	permission	from	relative	property	owners	will	be	obtained	

prior	to	UAS	flight.

8. All	permits,	permissions	and	insurance	will	be	obtained	prior	to	UAS	flight.

9. The	UAS	will	operate	speeds	less	than	87	knots.

10. The	UAS	will	operate	with	typical	return-to-base	failsafe	features.

11. The	UAS	will	not	operate	over	densely	populated	areas,	traffic	routes	or	within	5	

nautical	miles	of	any	airport	of	restricted	area.

18THIRTY	Entertainment	requests	Exemptions	from	the	following	CFRs:	

1.	91.9(b)(2),	91.203(a)	and	(b):	Carrying	Aircraft	Flight	Manual,	Certification	and	

Registration	in	the	Aircraft	

Given	the	small	size	of	the	proposed	UAS	platforms,	18THIRTY	Entertainment	requests	

that	these	materials	be	kept	in	the	vicinity	of	the	ground	control	station	during	flight.	
2.	91.7(a):	Civil	Aircraft	Airworthiness	

18THIRTY	Entertainment	requests	that	no	Airworthiness	Certificate	be	required.	

3.	91.9(c),	45.23(b),	and	45.27(a):	Aircraft	Marking	and	Identification	Requirements	

18THIRTY	Entertainment	requests	that	proposed	platforms	bear	registration	numbers	

that	are	as	large	as	practical	in	accordance	with	platform	size.	

4.	61.23(a)	and	(c),	61.113,	61.101(e)(4)	and	(5),	61.315:	Private,	Recreational	and	Sport	

Pilot	Medical	Certificate,	Privileges	and	Limitations	

18THIRTY	Entertainment	seeks	an	exemption	from	these	CFRs	as	they	prevent	private,	

recreational	or	sport	pilot	certificate	holders	from	receiving	pay	for	piloting	duties.	The	

UAS	platforms	in	this	petition	will	not	carry	passengers	or	cargo,	and	the	FAA	has	

previously	ruled	(Exemption	No.	11062)	that	a	Commercial	Pilot	Certificate	is	not	

required	for	UAS	operations	outside	of	controlled	airspace.	

5.	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	(2);	91.417(a)	and	(b):	Maintenance	

Inspections	

18THIRTY	Entertainment	seeks	exemptions	to	these	CFRs	as	they	are	intended	for	

aircraft	that	have	an	airworthiness	certificate.	18THIRTY	Entertainment will	ensure	that	

all	UAS	platforms	and	components	have	an	adequate	maintenance	and	inspection	

schedule.	

6.	91.121:	Altimeter	Settings	

18THIRTY	Entertainment seeks	an	exemption	from	the	requirement	that	a	pilot	

maintains	a	flight	level	through	reference	to	an	altimeter.	The	FAA	has	previously	stated	

that	equivalent	functionality	can	be	achieved	when	flights	occur	at	or	below	400	feet	

AGL	and	when	GPS elevation	data	can	be	transmitted	in	real	time	to	a	ground	control	

station,	given	that	a	PIC	establishes	GPS	elevation	accuracy	on-the-ground	prior	to	every	

flight.	
7.	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

18THIRTY	Entertainment seeks	an	exemption	from	the	requirement	that	fuel	reserves	

during	VFR	require	that	no	less	than	30	minutes	of	fuel	be	maintained	during	the	day	

and	45	minutes	during	the	night.	Given	that	the	platforms	in	this	petition	generally	have	

a	20	minute	or	less	flight	time that	is	powered	by	batteries	and	not	fuel,	no	meaningful	

flights	would	occur	under	91.151(a).	Exemption	No.	11213	determined	that	an	

equivalent	level	of	safety	is	evident	in	UAS	flights	where	the	operational	flight	time	can	

be	achieved	with	an	additional	five	minutes	of	flight	time	being	available	in	fuel/battery	

reserves.	

Please	contact	our	office	should	you	have	any	additional	questions	or	comments.	Thank	

you	for	your	consideration	with	this	request.

Sincerely,

Jeff	Aiello