Petition for Exemption 14 CFR § 11.81 Exemption petition under SEC 333 Your name and mailing 

address. You may include other contact information such as a fax number, telephone number, or 

email address;

Name: John Guarino, Shufflebox Productions, LLC

Address: 15525 Kutztown Rd. Suite C Kutztown, PA 19530

Phone: 484-648-2690

Email: info@shuffleboxproductions.com

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I am the owner of a 

commercial photo/video production company who is petitioning for an exemption to provide a 

commercial service to private land owners, companies, and service providers who wish to capture aerial 

photos and videos of their owned private property for purposes including real estate endeavors, event 

documentation, and for use as a marketing tool for business. I would like to be able to accept payment 

for these services therefore making this a commercial use of a UAS.

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for corporations, business 

owners, agents of real estate and law, and any other individuals who wish to document their land or 

property using the very unique capabilities the UAS provides, and allows them to do so using an 

experienced RC operator that understands how to safely fly such technology.

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 rule;

Being an experienced RC UAS operator I would be a good candidate for exemption of Sec 333 while not 

putting Air Safety in any accelerated risk. The specific UAS (Phantom II Quadcopter) I am seeking 

exemption with is equipped with safety features, including GPS stability and navigation, as well as, realtime flight status and emergency LED beacons. When flying, I would generally be flying at a maximum 
altitude of 150ft in a very small and limited zone with slow movements, decreasing the risk of any 

interference. My general knowledge of the FAA’s safety systems would be used to ensure that safety 

would not be affected by my operations. I would not be flying near disaster areas, sporting events, or 

high traffic areas including airports. 

Summary

I, John Guarino am seeking an exemption of Sec 333 of the FAA’s rules that does not allow the use of an 

Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safety. I am 

petitioning for an exemption to provide a commercial production service to private land owners and 

companies who wish to obtain and capture aerial photo and video of their property for purposes 

including real estate endeavors, event documentation, and for use as a marketing tool for business. I am 

an experience operator and technician with several hours of flight experience in varying conditions. I 

would be a good candidate for exemption of Sec 333 and would not put air safety at risk. The specific 

UAS (Phantom II Quadcopter) I am seeking exemption with is one with many safety programs, including 

GPS stability and navigation, as well as, real-time flight status and emergency LED beacons. When flying 

for this commercial purpose, I would generally be flying at a maximum altitude of 150ft in a very small 

and limited zone with slow movements, decreasing the risk of any unsafe flight. My general knowledge 

of the FAA’s safety systems would be used to ensure that safety would not be affected by my 

operations. . I would not be flying near disaster areas, sporting events, or high traffic areas including 

airports. I appreciate the FAA’s consideration and time reading this petition for exemption.

Any additional information, views, or arguments available to support your request;

Additionally, I have a 2 million dollar liability insurance policy covering commercial use of the UAS listed in 

this petition. Thank you again for your consideration.