Menajerie Studio

Attn: Nick Taylor

903 French Street

Erie, Pa, 16501

(814) 392-8514

August 10, 2015

U.S. Department of Transportation

Docket Operations West Building Ground Floor

Room W12-140 1200 New Jersey Avenue

SE Washington, DC 20590 

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

Regulations from certain parts of the FARs. 

Dear Sir or Madame, 

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

Part 11, Menajerie Studio, LLC, professional photography and videography company, hereby applies for 

an exemption from the listed Federal Aviation Regulations ("FARs") to allow its trained sUAS operators to 

operate a small Unmanned Aircraft System ("UAS") under the conditions and limitations set forth in this 

petition. 

The proposed exemptions, if granted, would allow Petitioner to operate the following UAS:

 DJI Inspire 1

 DJI Phantom 3

 3DR Solo Drone

 Other commercially available, small, camera-mounted unmanned aircraft systems ("UAS") 

weighing 55 pounds or less and meeting all of the required specifications set forth by the FAA.

These UAS would be used for the purpose of aerial filming of closed set motion pictures, music videos, 

web videos, corporate videos, television programs and commercials, still photography, surveying, 

agricultural observation, and real estate services. The requested exemption would permit the operation 

of small, unmanned sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, 

and (3) would provide safety enhancements to the already safe photography operations presently using 

manned helicopters and airplanes in Erie. 

Approval of the petitioner’s exemption would thereby enhance safety and fulfill the FAA Administrator's 

responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act." 

Regulations from which the exemption is requested: 

14 CFR Part 21

The requirement to display a registration number on the aircraft in not feasible due to insufficient space 

on drones that fit the limitations in size and weight.
14 C.F.R. § 45.23(b) 

The Aircraft certification requirements and procedures were designed for manned aircraft and not 

practicable for the proposed UASs. 

14 CFR § 61.3 

The requirement for a Pilot Certificate is more applicable for manned aircraft that carry people. Adequate 

training procedures for operating the drones will be required for any PIC that operates the vehicle. If an 

exemption is not granted, a PIC with a pilot license will be procured for oversight of the UAS’s operation.

14 C.F.R. § 91.7 (a) 

The Airworthiness requirement is applicable to manned aircraft, and not suitable to the proposed UAS.

14 CFR § 91.9 (b) (2) 

The requirement for the manual to be available in the cockpit is applicable to manned aircraft. The 

manufacturers’ manuals for the various UAS will be available on site for the PIC on any and all flights of 

the UAS.

14 C.F.R. § 91.103 

The requirement for crew members to be on board is applicable to manned aircraft. There will be a 

ground crew consisting of a minimum of the PIC and the VO.

14 C.F.R. § 91.109 

The requirement for Dual controls is applicable to manned aircraft. The UAS will be controlled remotely 

from the ground.

14 C.F. R. § 91.119 

The minimum altitudes for safe flight are applicable to manned aircraft. To replicate the level of safety 

the UAS will be flown at a maximum altitude of 400ft, and an adequate distance from all airports, 

buildings, persons, and physical obstacles.

14 C.F.R. § 91.121 

The Altimeter settings will be displayed on the FPV screen of the UAS controller

14 CFR § 91.203 (a) & (b)

The requirement for the registration and airworthiness certificates to be onboard are applicable to 

manned aircraft. Given the specifications of the aircraft, the petitioner asks for exemption from these 

requirments.

14 CFR § 91.205(b)

The Cockpit instruments requirement is applicable to manned aircraft. All of the controls and gauges will 

be monitored from ground level through the FPV controller.

14 CFR § 91.215 
The Transponder equipment requirement is applicable to manned aircraft, and the propsed UAS will be 

operated below the ATC coverage area.

14 CFR § 91.405 (a) 

The Inspection requirements are applicable to manned aircraft. The recommended maintenance will be 

performed as per the manuals accompanying the UAS.

14 CFR § 407 (a) (1) 

The Inspection approval requirements are applicable to manned aircraft. The manuals provided with the 

UAS are designed specifically for each system.

14 CFR § 409 (a) (2) 

Airworthiness Inspection is applicable to manned aircraft. The UAS will be routinely inspected for any 

damaged equipment before each flight.

14 CFR § 417 (a) & (b) 

The Maintenance records requirement is applicable to manned aircraft. Safety will be maintained by 

ensuring preflight maintenance occurs as per the manufacturer’s instructions.

The Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) of the Reform Act, 

which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making t the petitioner’s determination, the Administrator must 

determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat 

to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles "may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system." ld. § 333(c) (emphasis added). 

The Secretary has delegated the petitioner’s aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory 

requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The 

Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of t the petitioner’s section or any sections 44702-44716 of the Federal Aviation Act if 

Administrator finds 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). 
The petitioner has years of experience as a digital photographer and videographer, both as a profession 

and hobby, and has experience operating small UAS for recreational purposes. Menajerie Studio has 

always been at the leading edge of digital photography and video production. They were the area’s first 

Google certified Trust Photographers, bringing revolutionary Google Streetview Technology to the 

interiors of local businesses through the Google Business View virtual tour program. The Petitioner 

currently has practiced flying various UAS models under 50 pounds, under 35 miles per hour, under 400 

feet, for total of forty hours over remote areas of the Erie metropolitan area and over remote locations in 

NW Pennsylvania. To further expand Menajerie Studio’s suite of services offered to local businesses in 

Erie, PA, the petitioner wishes to monetize the use of its UAS for photographic and video purposes.

Many competitors of Petitioner are actively flying sUAS to conduct aerial photography for commercial 

purposes, notwithstanding the FAA's stated prohibition. The petitioner also notes and has read the 

congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the 

FAA move quickly to accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal 

Aviation Act, and the FARs rules to undertake the following activities for commercial purposes. Unless the 

Petition is granted, Petitioner will be at a significant competitive dis-advantage if he, as the petitioner 

prefers, complies with FAA policy. 

Vehicle 

The Petitioner will fly various small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 

pounds or less, at a speed no greater than 50 knots. T the petitioner’s vehicle has built in capability to 

limit the height it flies above the ground, to limit the radius of the distance it flies from the operator, and 

to exclude it from class B, C, and D airspace. The vehicle also has the built-in capability to return to the 

launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the 

height, radius, or airspace limitations programmed into it. It has a top speed of about 30 knots, carry 

neither a pilot nor passenger, carry no explosive materials or flammable liquids, and operate exclusively 

within a predetermined area. All have four fixed pitch rotors, thrust from which is varied by changing 

RPM. It is powered by a lithium polymer battery. 

Flight Profile 

The petitioner will not fly UAS above 400 feet above ground level, or more than 1500 feet away from him.

The petitioner will carefully preflight check the vehicle before each mission to assure that its navigation 

system are properly calibrated and that any included return-to-home features, altitude, and radius 

limitations work . 

The PIC will operate the vehicle for aerial photography missions only in the early morning hours and other 

times when few people are out in the public, but not at night or when visibility is reduced. The petitioner 

will operate it only over largely unpopulated areas where the potential of uncontrolled descent to cause 

injury or damage is lowest. The petitioner will not operate it in controlled airspace whatsoever, without 

express written consent from the FAA. In the unlikely event that a manned aircraft flies below 400 feet 

AGL where the petitioners operating the petitioner’s Phantom, Solo, or similar UAS the petitioner will 

keep both the vehicle and manned aircraft in sight and avoid the manned aircraft. 

More particularly, the Petitioner will fly UASs only over the following types of areas in Metropolitan
Erie: 

• Over Lakes and various waterways of Erie and the state of Pennsylvania, outward of the shoreline 

• Over open water in marinas, anchorages, and rivers amongst and surrounding the city of Erie

• Over lines of railroad and rail classification yards 

• Over metropolitan Erie parks 

• Over nonresidential and noncommercial large-scale industrial areas 

• Over private property when the petitioner has been commissioned by the person in legal possession of 

the property to do so 

• Over public or private events petitioner is hired as photographer. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act 

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security. The Petition justifies grant of the requested 

exemptions allow the Petitioner to obtain aerial photography with the petitioner’s UAS. 

Sincerely, 

Nick Taylor

Managing Partner, Menajerie Studio