U.S. Department of Transportation September 23, 2015

pg. 1

Lenzworks Productions

Dan Debenham

Tom C. Zdunich

2469 E Fort Union Blvd #212

Salt Lake City, UT 84121

U.S. Department of Transportation 

Docket Management System 1200 

New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 

CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Lenzworks

Productions, Dan Debenham and Tom C. Zdunich, operators of Small Unmanned aircraft Systems, hereby apply

for an exemption from the listed Federal Aviation Regulations to allow commercial operation of an 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.

Commercial operation sUAS, as described herein, which are equipped with cameras and sensors, would operate 

in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

4. Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested 

it by contract or donation. 

5. The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of sUAS for the purpose of the safe 

operation of sUAS to enhance the safety of the National Airspace System (NAS) as well as for the 

protection of the persons and property.
U.S. Department of Transportation September 23, 2015

pg. 2

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

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in 

the national airspace system.”

The name and address of the applicant is:

Lenzworks Productions

Attn: Dan Debenham

Attn: Tom C. Zdunich

Ph: (801) 261-1001

Email: Dan@Lenzworks.com

Address: 2469 E Fort Union Blvd #212 Salt Lake City, UT 84121

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113(a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

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) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b)

The sUAS’s I will be using are multi-rotor craft weighing no more than 55lbs. including payload. Under normal 

conditions they operate at speeds of no more than 100 Mph or 87 Knots and have the ability hover and move 

along a vertical and horizontal plane simultaneously. They will operate in line of sight only and by the exempted 

person only obeying all other local and federal laws.

Given the small size of the sUAS and the controlled environment provided the proposed operations will adhere 

to the Reform Act’s safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay.
U.S. Department of Transportation September 23, 2015

pg. 3

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% 

battery power reserve or 30 minutes of flight time whichever occurs first. 

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more 

than 200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer (VO) when needed

and may include but not limited to a Camera Operator. 

6. The sUAS pilot will be an FAA Certified Pilot ONLY not allowing any other person to operate the sUAS in 

a commercial capacity unless approved by exemption holder, trained and FAA certified. 

7. A briefing will be performed regarding the planned sUAS operations prior to each day’s flight consisting 

of all the days’ production activities. 

8. The operator will obtain verbal/written consent of all persons involved with the planned operation and 

ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the 

radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required 

under the FOM. With the advanced permission or direction of the FSDO, operations at closer range may 

be approved. 

9. The PIC and VO will have been trained in operation of sUAS and receive up-to-date information for the 

particular sUAS to be operated and will be able to show upon request their competent ability to operate 

the sUAS and/or Camera.

10. The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

11. Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies when needed. 

12. If the sUAS loses communications or loses GPS signal, the sUAS will have the capability to return to a 

pre-determined location within a designated location and land autonomously. 

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft 
U.S. Department of Transportation September 23, 2015

pg. 4

from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these 

criteria demonstrates that the sUAS 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 without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety requirements. These safety 

enhancements provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security posed by the 

sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the 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 or provisionally 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 more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have 

no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the 

size of the sUAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the 

identification of the sUAS as “Experimental.” 

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

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command of 

an aircraft that is carrying passengers or property for compensation or hire. Our sUAS do not carry any pilots or 

passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s 

license will not ensure remote control piloting skills. The risks attendant to the operation of sUAS is far less than 

the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set 

forth in the FOM will equate to the safe operation of the sUAS.

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 
U.S. Department of Transportation September 23, 2015

pg. 5

standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety 

checklists prior to each flight an equivalent level of safety will be provided. 

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

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 of this 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 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 of safety will be maintained by keeping the flight manual 

at the ground control point where the pilot flying the sUAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The 

PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data before initiation of flight. 

14 C.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 for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted 

aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use 

of a control box that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes for operation of civil 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 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 set 

forth herein, the sUAS will never operate at higher than 400 AGL with the exception that in circumstances where 

the sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS will not be 

operated more than 100' above the highest point on the structure. It will however be operated in a restricted 

area with security perimeter, where buildings and people will not be exposed to operations without their preobtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as 

well as the location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming activity, all 
U.S. Department of Transportation September 23, 2015

pg. 6

affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft operating 

at or below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these 

small- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

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

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 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.” The battery powering the sUAS provides approximately 30 

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 10 minutes in length. Given the limitations on the sUAS’s proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or 

Twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only people and 

property owners or official 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 of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility 

for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power— whichever 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.

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 has within 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) 

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 sUAS 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 or to display them on the sUAS. 
U.S. Department of Transportation September 23, 2015

pg. 7

An equivalent level of safety 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 extent they are applicable to the sUAS. 

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the 

aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any 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 of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the sUAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As

provided in the FOM, the operator will ensure that the sUAS is in working order prior to initiating flight and 

perform required maintenance needed.

sUAS Information

sUAS’s to be used are as follows but not limited to providing they are within the scope of the exemption granted 

by the FAA:

1. DJI Inspire

 Weight (Battery Included) 2935g

 Hovering Accuracy (GPS Mode) Vertical 0.5m, Horizontal 2.5m

 Max Angular Velocity Pitch: 300deg/s; Yaw 150deg/s

 Max Tilt Angle 30deg/s

 Max Ascent Speed 5m/s

 Max Decent Speed 4m/s

 Max Speed 22m/s

 Diagonal Distance 559mm (Landing gear lowered), 581mm (Landing gear raised)

a. DJI Inspire Gimbal

 Operating Current - Station: 750mA, Motion: 900mA

 Controllable Range - Pitch: -90deg to +30deg

 Max Controllable Speed – Pitch: 120deg/s, Pan: 180deg/s
U.S. Department of Transportation September 23, 2015

pg. 8

b. DJI Inspire Battery

 Model (Standard) TB47

 Voltage 22.2v

 Capacity 4500mAh

 Energy 99.9Wh

 Net Weight 570g

c. DJI Inspire Remote Controller

 Frequency 

o 5.725GHz~5.850GHz (Remote Controller to Remote Controller)

o 2.400GHz~2.483GHz (Remote Controller to Aircraft)

 Battery Capacity 6000mAh

 Working Current/Voltage 1.2A@7.4V

Conclusion,

The use of sUAS’s provide many benefits to the general public, such as: Decreased air pollution due to the 

enormous amount of leaded fuel needed to fly manned aerial vehicles, decreased noise pollution when near the 

public, Decreased air traffic congestion at airports and provides a more affordable and reasonable alternative to 

current options available to the consumer. As for safety, Small Unmanned Aerial Systems do not carry people or 

property so it provides less of a chance of injury in the case of an accident and because of the size and weight of 

manned aircraft the ground casualties can be far less or nonexistent in the case of a downed sUAS vs a manned 

aircraft.

Thank you for the consideration of these exemptions.

Sincerely,

Dan Debenham

Tom C. Zdunich

Lenzworks