John Baer September 17, 2015

PDM Pictures, Inc.

25 Banbury Ct.

Trenton, NJ 08691

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Petition of Exemption Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012

Dear Sir or Madam:

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

Part 11, John Baer, owner PDM Pictures, Inc., private pilot and owner/operator of small 

unmanned aircraft systems hereby applies for an exemption from the Federal Aviation 

Regulations identified below to allow for the commercial operation of the DJI Phantom 

2 and the DJI 550 for the following: (1) Aerial photography and/or video for use in real 

estate, construction and architecture: (2) Aerial photography and/or video for 

television, public events, cinematography and news gathering; (3) Aerial video to 

provide live video assistance with law enforcement and search & rescue operations only 

when the local authorities or government has requested it by contract or donation. (4) 

Training persons in the safe use and operations of a small unmanned aerial systems.

Thank you,

John Baer

President

PDM Pictures, Inc.
I. DESCRIPTION OF PETITIONER

PDM Pictures, Inc.

John Baer - President

25 Banbury Ct.

Trenton, NJ 08691

Phone: 609-947-7205 Email: exnikon@aol.com

John Baer, President of PDM Pictures, Inc., is a professional photographer for over 25 

years, a private pilot for over 15 years and a remote control pilot for over 7 years. PDM 

Pictures, Inc. primarily provides photographic and video services to the construction and 

real estate industry.

II. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

PDM Pictures, Inc. requests an exemption from the following regulations: 

- 14 C.F.R. Part 21, Subpart H and 14 C.F.R. § 91.203

- 14 C.F.R. Part 27 

- 14 C.F.R. § 45.23(b), 45.27(a) and 91.9(c) 

- 14 C.F.R. § 61.113 

- 14 C.F.R. § 91.9(b)(2)

- 14 C.F.R. §§ 91.203(a) and (b)

- 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b)

- 14 C.F.R § 91.7(a)

- 14 C.F.R. § 91.103

- 14 C.F.R. § 91.109(a)

- 14 C.F.R § 91.119;

- 14 C.F.R § 91.121;

- 14 C.F.R. § 91.151(a

III. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Federal 

Aviation Administration (FAA) Modernization and Reform Act of 2012 (Reform Act). 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system.” Pursuant to the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system (UAS) where it 

does not create a hazard to users of the National Airspace System (NAS) or the public or 

pose a threat to national security based on the following considerations: (1) The size, 

weight, speed and operational capability of the UAS; (2) Operation of the UAS in 

proximity to airports and populated areas; and (3) Operation of the UAS within visual 

line of sight of the operator.
Furthermore, the Reform Act grants the FAA Administrator general authority to grant 

exemptions from the agency’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. A party 

requesting an exemption must explain the reasons why the exemption: (1) would 

benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules. See 14 C.P.R. § 11.81.

IV. DESCRIPTION OF PROPOSED OPERATIONS OF PDM PICTURES, INC.

PDM Pictures, Inc. intends to fly the DJI Phantom 2 and DJI 550. These UAS's will be 

flown with strict adherence to all operating and safety manuals.

A. DJI PHANTON 2

1) DJI is a world leader in innovation and manufacturing of UAS. DJI has a wellknown commitment for creating small, safe, easy to operate and efficient 

lightweight multi-rotor battery powered aircraft.

2) Specifications of the DJI Phantom 2:

 a) 350mm inches (diagonal - motor to motor)

 b) Maximum weight (including payload): 3.1 lbs.

c) Maximum horizontal Speed 29 Knots: (15 m/s)

d) Maximum flight time: 20 minutes

e) RF control range: 1,000 meters

f) Quad-rotor electric propulsion system

g) Safety rotor guards

h) Power source is a removable/rechargeable battery system

i) Red and green LED navigation/information lights beneath the aircraft 

that differentiate front/rear and alert the operator of loss of GPS signal

j) DJI Naza-M V2 intelligent flight control system

k) Global positioning system (GPS)

l) Digital compass

m) 2.4 GHz (flight controller)

n) 5.8 GHz (video and data communication)

o) All RF components are FCC certified

p) Digital camera and camera gimbal

3) DJI Phantom 2 Safety Features:

a) Equipped with safety rotor guards to prevent/reduce injury/damage in 

the event of accidental impact with persons or property.

b) Onboard DJI Naza-M V2 Intelligent Flight Control System with built-in 

GPS providing accurate position information.

c) Real-time flight telemetry date to include: altitude, flight speed, 

distance from the pilot, number of GPS satellites in view and battery 

level power for flight.

d) When the battery level is reduced to below 25% the DJI Phantom 2 will 

begin an automatic descent and landing. Upon landing the motors will 
stop, the Phantom 2 will not crash upon inadvertent exhaustion of its 

power source.

e) An on-screen display provides real time location, heading relative to 

the pilot, altitude and power level to the PIC.

f) The intelligent Flight Control System coupled with the GPS position 

information onboard the DJI Phantom 2 provides the ability for the pilot 

to auto-hover in position with compensation for wind and drift and 

at the discretion of the pilot.

g) The intelligent Flight Control System coupled with the GPS position 

information onboard the DJI Phantom 2 provides the ability for the pilot 

to command the UAS to automatically return to its point of departure.

h) The DJI Phantom 2 will return to its point of departure, land and shut 

down the motors automatically in the event of a loss of RF control.

B. DJI 550

1) DJI is a world leader in innovation and manufacturing of UAS. DJI has a wellknown commitment for creating small, safe, easy to operate and efficient 

lightweight multi-rotor battery powered aircraft.

2) Specifications of the DJI 550:

a) 550 mm (diagonal - motor to motor)

b) Maximum weight (including payload): 5.4 lbs.

c) Maximum horizontal Speed 29 Knots: (15 m/s)

d) Maximum flight time: 8 minutes

e) RF control range: 1,000 meters

f) Hex-rotor electric propulsion system

g) Power source is a removable/rechargeable battery system

h) Blue and white LED navigation lights that differentiate front/rear

i) DJI Naza-M V2 intelligent flight control system

j) Global positioning system (GPS)

k) Digital compass

l) 2.4 GHz (flight controller)

m) 5.8 GHz (video and data communication)

n) All RF components are FCC certified

o) Digital camera and camera gimbal

3) DJI 550 Safety Features:

a) On board DJI Naza-M V2 Intelligent Flight Control System with built-in 

GPS providing accurate position information.

b) Real-time flight telemetry date to include: altitude, flight speed, 

distance from the pilot, number of GPS satellites in view and battery 

level power for flight.

c) When the battery level is reduced to below 25% the DJI 550 will begin 

an automatic descent and landing. Upon landing the motors will stop, the 

DJI 550 will not crash upon inadvertent exhaustion of its power source.

e) An on screen display provides real-time location, heading relative to 
the pilot, altitude and power level to the pilot/operator.

f) The intelligent Flight Control System coupled with the GPS position 

information onboard the DJI 550 provides the ability for the pilot to autohover in position with compensation for wind and drift and at the 

discretion of the pilot.

g) The intelligent Flight Control System coupled with the GPS position 

information onboard the DJI 550 provides the ability for the pilot to 

command the UAS to automatically return to its point of departure.

h) The DJI 550 will return to its point of departure, land and shut down 

the motors automatically in the event of a loss of radio control.

These two UAS's are extremely similar in operation, both run on Naza-M V2 Intelligent 

Flight Control System and both are controlled by the same radio transmitter, the only 

real difference is the additional two motors in the DJI 550 which allows for an extra 2.3 

lbs of payload. The highly advanced control systems, electronics and engineering will 

allow the UAS to safely operated in the NAS and will not create a hazard to the public. 

C. OPERATIONS OF THE DJI PHANTOM 2 & DJI 550

1. Prior to each flight, the pilot in command (PIC) will inspect the UAS to ensure 

it's in a condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft will be prohibited from operating until 

the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The remote control radio will be included in the 

preflight inspection.

2. The PIC will have a private pilot's license and current 3rd Class medical 

certificate and will have sufficient experience and training to safely fly the UAS

3. Flights will be operated at or below 200 feet AGL.

4. The UAS will weigh less than 10 lbs.

5. The UAS flight speed will not exceed a speed of 29 knots.

6. The UAS will be operated within Visual Line of Sight (VLOS) of the PIC at all 

times. This requires the PIC to use human vision unaided by any device other 

than corrective lenses.

7. Before conducting any flight operations, the radio transmitter will be 

inspected to comply with Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

8. The PIC will ensure that no persons in open areas are allowed within 100 feet 

of the aircraft except those consenting to be involved and are necessary for the 

aerial photography operations.

9. UAS operation will be completed prior to battery levels reaching 25% capacity.

10. The UAS will remain clear and yield the right of way to all other manned 

operations and activities at all times.

11. No night time UAS operations will be conducted.

12. All operations will be conducted under visual meteorological conditions 

(VMC). No flight will be authorized under special visual flight rules (SVFR).
13. The UAS will not be operated from any moving device or vehicle.

14. The UAS will not operate in Class B, C, or D airspace without written 

approval from the FAA. The UAS will not operate within five nautical miles of 

the geographic center of a non-towered airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s 

management is obtained. The letter of agreement with the airport management 

will be made available to the Administrator upon request.

15. A briefing will be conducted in regard to the planned operation prior to each 

flight. It will be mandatory that all personnel who will be performing duties with 

in the boundaries of the safety perimeter be present for this briefing and it will 

include a comprehensive flight plan and safety information regarding the flight.

16. Contingency plans will be in place to safely terminate flight if there is a loss 

of communication between the PIC and the observer(s).

17. Each flight will be recorded in the PIC's Pilot Log Book.

V. SPECIFIC REGULATIONS FROM WHICH EXEMPTION IS REQUESTE

PDM Pictures, Inc. seeks an exemption from several provisions of 14 C.F.R. Parts 21, 27, 

45, 61, and 91 for purposes of conducting the requested operations using the DJI 

Phantom 2 and the DJI 550. Listed below are the specific sections for which exemption is 

sought, and the operating procedures and safeguards that will be followed by PDM 

Pictures, Inc. to ensure a level of safety at or better than the rules from which 

exemption is sought.

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

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. These criteria are met, and 

therefore no exemption is needed. If, however, the FAA determines that there are some 

characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, 

then an exemption is requested.

Equivalent Level of Safety: The UAS's listed in Section IV (A and B) are safe when taking 

into account its size, weight, speed, and operational capability. Both UAS's weigh less 

than 10lbs pounds and will be flown at speeds of less than 29 knots, in visual line of 

sight of the operator, and outside controlled airspace. Additionally, they do not carry 

pilots, passengers, explosive materials, or flammable liquid fuels and will not pose a 

threat to national security. PDM Pictures, Inc. will also provide the FAA with advance 

notice of all operations via Notice to Airman (NOTAM) in coordination with the local 

Flight Standards District Office (FSDO). The proposed operations will be at least as safe 

as, or safer than, conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

B) 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification 
of normal category rotorcraft. To the extent the UAS's listed in Section IV (B and C) 

would otherwise require certification under Part 27, PDM Pictures, Inc. seeks an 

exemption from Part 27’s airworthiness standards for the same reasons identified in the 

request for exemption from 14 C.F.R. Part 21, Subpart H. 

C) 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements

14 C.F.R. §45.23(b), 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. 14 C.F.R. § 45.27(a) states: Rotorcraft. 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 14 C.F.R. § 

91.9(c) states: No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with part 45 of this chapter. In a previous Grant of 

Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft, “have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable.”

Equivalent Level of Safety: PDM Pictures, Inc. will mark their UAS's with an assigned Nnumber in a prominent area on the UAS with markings that are as large as practicable.

D) 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

PDM Pictures, Inc. seeks exemption from 14 CFR § 61.113, which restricts private pilots 

from flying aircraft for compensation or hire and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of 

any PIC matches the airspace in which the PIC will be operating, as well as requiring 

certifications if the pilot is carrying passengers or cargo for hire. While the DJI Phantom 

or DJI 550 will be operated as part of a commercial operation, it carries neither 

passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the 

FAA determined that the unique characteristics of UAS operation outside of controlled 

airspace did not warrant the additional cost and restrictions attendant with requiring 

the PIC to have a commercial pilot certificate and a Class II medical certificate. The FAA 

has also determined that the required knowledge for a commercial pilot covers the 

same fundamental principles as a private pilot. The FAA stated in its grant of an 

exception to Astraeus Aerial the “the FAA considers the overriding safety factor for the 

limited operations proposed by the petitioner to be the airmanship skills acquired 

through UAS-specific flight cycles, flight time, and specific make and model experience, 

culminating in verification through testing.”

Equivalent Level of Safety: The restrictions PDM Pictures, Inc. has placed on its 

operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA 

Docket No. FAA-2014-0352. PDM Pictures, Inc. will operate in areas away from people 

and property who are not involved in the UAS flight operation. The aircraft will be flown 
with VLOS at or below 200 feet AGL and in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. The PDM Pictures, Inc. PIC must have 

accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 

200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten 

hours logged as a UAS pilot with a similar UAS type. PDM Pictures, Inc. also adheres to 

the Academy of Model Aeronautics (AMA) National Model Aircraft Safety Code. All PDM 

Pictures, Inc. pilots and visual observers are trained on the standards of this safety code.

E) 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a 

civil aircraft be in airworthy condition to be operated. The FAA has stated that no 

exemption is required to the extent that the requirements of Part 21 are waived or 

found inapplicable. Accordingly, PDM Pictures, Inc. requests that the requirements for 

Section 91.7 be treated in accordance with FAR Part 21 Subpart H.

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

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may operate a U.S.-registered civil 

aircraft - ... (2) For which an Airplane or Rotorcraft Flight Manual is 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. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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. 

PDM Pictures, Inc. does not request an exemption from this section but instead notifies 

the FAA that the UAS flight manual, registration certificate and other documentation 

will be kept with the PIC during flight. The Chief Counsel’s Office has held that for all 

UAS operations, this alternate method constitutes full compliance.

G) 14 C.F.R. § 91.103: Preflight Action

PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information 

contained in the FAA-approved Flight Manual on board the aircraft. While the aircraft 

will not have a Flight Manual on board, the PIC will be familiar with all information 

necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following 

the flight Manuals provided by the manufacturer. The PIC will take all required preflight 
actions - including performing all required checklists and reviewing weather, flight 

requirements, battery charge, landing and takeoff distance, aircraft performance data, 

and contingency landing areas - before initiation of flight. The Manuals will be kept at 

the ground station with the operator at all times

H) 14 C.F.R. § 91.109(a): Flight Instruction

PDM Pictures, Inc. seeks an exemption from 14 C.F.R. § 91.109(a), which 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.” UAS 

and remotely piloted aircraft, by their design, do not have functional dual controls. 

Instead, flight control is accomplished through the use of the DJI Naza-M V2 that 

communicates with the aircraft via radio communications.

Equivalent Level of Safety: Given the size and speed of the UAS being used by PDM 

Pictures, Inc., an equivalent level of safe training can still be performed without dual 

controls because no pilot or passengers are on board the UAS, and all persons will be a 

safe distance away in the event that the UAS experiences any difficulties during flight 

instruction. These training flights will primarily be conducted in a training facility which 

provides a secure perimeter with out public access. In addition, all training flights will be 

conducted by an experienced FAA certified Private Pilot with a current Class 3 medical 

certificate.

I) 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

PDM Pictures, Inc. requests an exemption from the minimum safe altitude requirements 

of 14 C.F.R. § 91.119. Section 91.119(c) prescribes that an aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure in non-congested areas. 

Section 91.119(d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes 

or altitudes specifically prescribed for helicopters by the FAA."

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far 

more than the maximum weights proposed herein, and given the lack of flammable fuel, 

any risk associated with these operations is far less than those that presently exist with 

conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS's, as well as the locations where it is operated. In order to 

avoid any risk to aircraft, flight operations will be restricted to at or below 200 feet AGL. 

As set forth in the Manuals and herein, the UAS will be operated in areas away from 

persons or structures not involved in the operation.

J) 14 C.F.R. § 91.121: Altimeter Settings

PDM Pictures, Inc. requests an exemption from 14 C.F.R. § 91.121, which requires a 

person operating an aircraft to maintain cruising altitude or flight level by reference to 

an altimeter that is set to the elevation of the departure airport or barometric pressure. 

An exemption is requested to the extent that the UAS does not have a barometric 

altimeter, but rather a GPS altitude read out.
Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 200 feet AGL and within visual lineof-sight. This will be accomplished as the altitude of the aircraft is monitored by the PIC 

and by the visual observer, in addition, the PIC will have GPS based altitude information 

relayed in real time to the ground station.

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

PDM Pictures, Inc. requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements 

for flight in VFR conditions. Section 91.151 states: (a) No person may begin 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 technological 

limitations on UAS battery power means that no meaningful flight operations can be 

conducted while still maintaining a 30 minute reserve. PDM Pictures, Inc. proposes that 

the UAS will be safely landed with no less than 25% battery life remaining.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is 

provided if the UAS flight is conducted under daytime VFR flight conditions using VLOS, 

and terminated with at least 25% reserve battery power still available. The UAS 

Operations Manual conforms to this limit, providing an equivalent level of safety.

L) 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

PDM Pictures, Inc. seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 

43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft 

“[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections ... have discrepancies repaired as prescribed in part 43 of 

this chapter”). An exemption from these regulations is needed because Part 43 and 

these sections only apply to aircraft with an airworthiness certificate, which the UAS's 

will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because PDM 

Pictures, Inc. requires its PIC to conduct a through preflight flight and post flight 

inspection of the UAS to ensure it's flight worthiness. Each UAS is flown in compliance 

with the applicable manufactures manual to include maintenance, overhaul, 

replacement, and inspection requirements for the aircraft and procedures to document 

and maintain maintenance records for the aircraft. PDM Pictures, Inc. maintains log 

books for the UAS's which include all maintenance and/or alterations.

VI. PUBLIC INTEREST

Granting the exemption request of PDM Pictures, Inc. furthers the public interest. 
National policy set by Congress favors early integration of the UAS into the NAS in 

controlled, safe working environments such as those proposed in this petition. In 

addition, the public also has an interest in reducing the hazards and emissions 

associated with alternate use of helicopters to conduct similar operations. The UAS 

proposed for the exemptions are very light, with a total gross weight of less than 10 lbs. 

They do not carry any flammable liquid fuel, further reducing the risk from any potential 

accident.

Additionally, PDM Pictures, Inc. has the knowledge and expertise to safely and 

effectively photograph from within the NAS, whereby typical larger manned aircraft may 

be a hindrance to the public, noisy and not accessible. PDM Pictures, Inc. will have the 

capability to effectively dispatch in minutes a UAS that in most cases will go unnoticed 

by the general public, fall well below the typical noise signature of manned aircraft 

without the use of traditional petroleum based fuels. PDM Pictures, Inc. also encourages 

demonstrations and seminars relating to safe and effective UAS operation. As a former 

First Responder, it has become apparent that using a UAS in emergency operations is an 

efficient and useful tool, and in certain circumstances will be able to provide faster 

services and information than a tradition manned aircraft, all while providing a safe 

working environment. When requested, and in coordination with federal, state and local 

governments after a disaster, PDM Pictures, Inc. can provide valuable information to 

first responders and government agencies to help coordinate the response that may not 

be obtainable with traditional manned aircraft. Finally, PDM Pictures, Inc. is willing to 

donate its time to assist the FAA or any other government or public agency that wishes 

to educate the general public on the integration of UAS in NAS.

VII. PRIVACY

All flights will occur over private property or over controlled-access property, these 

flights will be conducted with the property owner’s consent and knowledge prior to the 

flight operation. Any photography will be of people who have consented to being 

photographed or otherwise have agreed to be in the area where the aerial photography 

operations will take place. All operations will be compliant with applicable federal, state 

and local laws. The Applicant’s request satisfies the criteria set forth in Section 333 of 

the Reform Act. The size, weight, speed, operating capabilities of the UAS, the limits on 

operations proximate to airports and populated areas, and the operation within VLOS 

do not create a hazard to users of the national airspace system and do not pose any 

national security threats or concerns.

VIII. SUMMARY FOR FEDERAL REGISTRY

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 PDM Pictures, Inc. 

seeks an exemption from the following rules: 14 CPR Part 21, Subpart H; 14 CPR Part 27; 

14 CPR 45.23(b); 14 CPR§ 61.113; 14 CPR 91.7(a); 14 CPR 91.9(b)(2); 14 CPR 91.103; 14 
CPR 91.109(a); 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.203 (a) & (b); 

14 CPR 91.405(a); 14 CPR 91.407(a)(l); 14 CPR 91.409(a)(2); 14 CPR 91.417 (a) & (b). The 

exemption, as requested by PDM Pictures, Inc., will enhance safety by reducing risk to 

the general public and property owners from the substantial hazards associated with 

performing equivalent work with conventional aircraft and rotorcraft.

IX. ATTACHMENTS

1) Pilot Logbook 

2) DJI Phantom 2 Manual

3) DJI 550 Manual

X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, 

speed, operating capabilities, proximity to airports and populated areas, operation 

within visual line of sight, and national security considerations - provides more than 

adequate justification for the grant of the requested exemptions to permit PDM 

Pictures, Inc. to operate the DJI Phantom 2 and DJI 550 for use in aerial photography 

and video. 

Granting the requested exemption will benefit the public interest as a whole in many 

ways: (1) significantly improving safety and reducing risk by alleviating human exposure 

to danger; and (2) improving the quality of services and decreasing operating costs 

associated with conventional flight operations. 

Respectfully submitted,

John Baer

PDM Pictures, Inc.