March 1, 2015

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 C.F.R. 21 Subpart H; 14 C.F.R. §45.23(b); 14 C.F.R. 

§61.113(a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2); 14 C.F.R. §91.103(b)(2); 14 

C.F.R. §91.109; 14 C.F.R. §91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. 

§91.203 (a) and (b); 14 C.F.R. §91.405 (a); 14 C.F.R. §91.407 (a) (1) 14 C.F.R. §91.409 (a)(1) 

and (2); 14 C.F.R. §91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform 

Act”) and 14 CFR Part 11, Eric C. Turner (“Applicant”), an operator of Unmanned Aircraft 

Systems (“UASs”), hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its 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 of a sUAS, as described herein, which are equipped with camera(s) and 

sensor(s), would operate in the following manner:

1. Aerial photography for the motion picture and television industry for scripted closed 

set filming.1

2. Aerial patrol/inspection and survey of commercial/residential utility infrastructure 

including but not limited to powerlines/pipelines, wind turbines, and cell towers.

3. Aerial video/photography or providing live video feed to assist with search and 

rescue operations, wild land firefighting support, wildlife and forestry monitoring, and 

law enforcement when local, state or federal authorities or government has 

requested it by contract or donation.

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

public/sporting events, cinematography and electronic news gathering (“ENG”).

5. Aerial video/photography for real estate, architecture, engineering, and survey.

6. Aerial data collection applications including but not limited to mapping, land 

surveying, precision agriculture, 3D modeling, R&D, and market research.

7. Crew member/cinematography training as well as the ability to offer training to 

persons individually or belonging to both private and/or public organizations that 

have interests in the safe use and operation of a UAS.

The requested exemption would permit the operation of a 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 

 1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver 

for Motion Picture and Television Filming.
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Transportation’s (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

The name and address of the applicant is:

Eric C. Turner

Phone: (310) 880-1474

Email: eturn23@me.com

Address: 432 E Spruce Ave #84, Inglewood, CA 90301

Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart H 14 C.F.R. § 91.119 (c)

14 C.F.R. Part 36 Subpart A, F & O 14 C.F.R. § 91.121

14 C.F.R. § 45.23 (b) 14 C.F.R. § 91.151 (a)

14 C.F.R. § 45.29

14 C.F.R. § 61.113 (a) & (b) 14 C.F.R. § 91.203 (a) & (b)

14 C.F.R. § 91.7 (a) 14 C.F.R. § 91.405 (a)

14	C.F.R.	§ 91.9 (b)(2) 14 C.F.R. § 91.407 (a)(1)

14 C.F.R. § 91.103(b)(2) 14 C.F.R. § 91.409 (a)(2)

14 C.F.R. § 91.109 14 C.F.R. § 91.417 (a) & (b)

Applicant proposes to operate the following sUASs:

- Freefly Systems ALTA

- DJI FlameWheel F550

- DJI Inspire 1

- DJI Phantom 3 Professional

UASs operated by Applicant weigh less than 55 pounds, including payload (i.e. camera, 

lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. Applicant will only operate its UASs in line of 

sight, will operate within the sterile area described in Applicant’s Flight Operations and Motion 

Picture and Television Manual (FOPM)2. Such operations will insure that the sUAS will “not 

create a hazard to users of the national airspace system or the public.”3

Similarly sized sUASs have been approved for use in prior Section 333 Grants of Exemption 

from the FAA. See e.g., Grant of Exemption to Astraeus Aerial (Exemption No. 11062); Grant of 

Exemption to Empire Unmanned, LLC (Exemption No. 11881); Grant of Exemption to 

ArrowData, LLC (Exemption No. 11408); Grant of Exemption to Alan Purwin (Exemption No. 

11161); Grant of Exemption to Helinet Aviation Services, LLC (Exemption No. 11160); Grant of 

Exemption to 4th Dimension Sight & Sound, Inc. (Exemption No. 12428); Grant of Exemption to 

Sensefly, Ltd. (Exemption No. 11263).

Given the small size of the sUASs 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 

 2 Applicant submits this manual as a Confidential document under 14 CFR 11.35(b) as the entire manual contains proprietary 

information that the applicant has not and will not share with others. The manual contains operating conditions and procedures that 

are not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et. seq.

3 Reform Act Section 333(b)
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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.

Aircraft and Equivalent Level of Safety

The Applicant seeks to have this exemption cover the sUASs used to carry out the 

commercial operations described herein which are subject to the limitations proposed in this 

petition. Applicant proposes and agrees to the following limitations and conditions for

commercial sUAS operations conducted under a granted FAA exemption:

1. The sUASs will weigh less than 55 lbs.

2. Flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO). 

3. Maximum flight time for a multi-rotor sUAS 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. Maximum flight time for a fixed wing sUAS operational flight will be 40 

minutes. Flights will be terminated at 25% battery power reserve or 30 

minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet AGL or, not 

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

6. Minimum crew for each operation will consist of the sUAS Pilot, the Visual 

Observer (VO), and may include but not limited to a Camera Operator.

7. The sUAS pilot will be a designated Pilot in Command (PIC) and hold either 

an airline transport, commercial, private, recreational, or sport pilot certificate. 

The PIC will also hold a current FAA airmen medical certificate or a valid U.S. 

driver’s license issued by a state, District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal government of the United States. The 

PIC will also meet the flight review requirements specified in 14 C.F.R. §

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. If a 

pilot certificate holder other than the sUAS pilot, who possesses the 

necessary PIC qualifications, is also present on set (i.e. the Aerial 

Coordinator), that person can also be designated as PIC.

8. During closed set filming for motion picture and television the sUAS will only 

operate within a confined “Sterile Area” as defined in the FOPM. The FOPM 

requires the establishment of a “Security Perimeter” for the flight operations 

area.

9. A briefing will be conducted for planned sUAS operations prior to each day’s 

flight. All personnel performing duties within the boundaries of the safety 

perimeter are required to attend.

10. All flights will occur under Visual Meteorological Conditions (VMC) only.

11. The flights will occur no closer than a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport.

12. If operations will be within a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport the 

respective airports will be contacted advising them of the estimated flight 

time, flight duration, elevation of flight and other pertinent information.

13. The operator will file FAA Form 7711-1, or its equivalent, as modified in light 

of the requested exemption, with the appropriate local Flight Standards 

District Office (FSDO).
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14. The operator will obtain consent of all persons involved in the filming and 

ensure that only consenting persons will be allowed within 100 feet of the 

flight operation. This radius may be reduced to 30 feet based upon an 

equivalent level of safety determination, as required under the FOPM. With 

the advanced permission of the FSDO, operations at closer range can be 

approved.

15. The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed shoot as required in the FOPM.

16. The PIC and VO must be trained in sUAS operations and have received 

current information on the particular sUAS to be operated as required by the 

FOPM.

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

18. Written and/or verbal permission from the relevant property holders will be 

obtained.

19. All required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.

20. If the sUAS loses communications or loses its GPS signal, the sUAS will 

have capability to return to a pre-determined location within the Security 

Perimeter and land.

21. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies.

22. The sUAS will not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC.

23. A Flight Operations and Motion Picture and Television Operations Manual 

(FOPM) will be used to help govern all closed-set motion picture and 

television filming operations. 

14 C.F.R. Part 21, Subpart H: Certification Procedures - Airworthiness Certificates

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 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 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 the operator in compliance with local public 

safety requirements. These enhancements provide a greater degree of safety to the public and 

property owners than conventional civil aircraft operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 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 its inability to carry a substantial 
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external load. There have been exemptions granted by the FAA to petitioners seeking identical 

relief; See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

14 C.F.R. Part 36, Subparts A, F and O: Noise Standards - Aircraft Type and 

Airworthiness Certification

Pursuant to 14 C.F.R. Part 36, Subparts A, F and O, establish certain noise standards 

for certification of various aircraft types. Because the Subject sUAS would not have an 

airworthiness certificate, and given its small size and negligible noise impact, the petitioner 

requests an exemption from 14 C.F.R. Part 36.

14 C.F.R. § 45.23 (b): Display of Marks; General.

Pursuant to 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.

While 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 impractical. 

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.” 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 C.F.R Part 45, Subpart C if the 

markings are as large as practicable.” See FAA Docket No. FAA-2014-0352. All sUASs flown by 

Applicant will bear N-number markings that are as large as practicable in accordance with 14 

C.F.R. Part 45, Subpart C.

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

Pursuant to 14 C.F.R. 61.113 (a) & (b); 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. Because the applicant’s sUAS does not carry any pilots, passengers, or 

property, Applicant may achieve an equivalent level of safety as achieved under current 

regulations. The risks attendant to the operation of a sUAS is far less than the risk levels

inherent in the commercial activities outlined in 14 C.F.R. 61. The PIC of the sUAS will have 

either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC 

will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, District of Columbia, Puerto Rico, a territory, a possession, or the Federal government of 

the United States. In meeting those limitations as listed in previous FAA exemption approvals, 

the PIC of Applicant’s sUASs will exceed current safety levels in relation to 14 C.F.R. 61.113 (a) 

& (b).

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

Pursuant to 14 C.F.R. 91.7(a); No person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the sUAS, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.
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Given the size of the aircraft and the maintenance requirements detailed in the sUAS User 

and/or Operations Manual combined with safety check lists prior to each flight, an equivalent 

level of safety will be provided. See Grant of Exemption No. 11671 to Dronair Solutions (FAA–

2015–0648 page 18) for previous FAA granted exemption.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard Requirements.

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. Given the size 

and configuration of the sUAS used by Applicant, there is no capacity to carry such a flight 

manual on the aircraft. An equivalent level of safety will be achieved by keeping the sUAS 

Operation Manual at the ground control point where the pilot in command will have immediate 

access. See

Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation 

and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket 

No. FAA-2014-0352 at 16-18.

14 C.F.R. § 91.103(b)(2): General Operating and Flight Rules - Preflight Action.

Pursuant to 14 C.F.R. 91.103(b)(2); For civil aircraft other than those specified in 

paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and runway slope, aircraft gross 

weight, and wind and temperature. An equivalent level of safety will be provided by a preflight

checklist and other safety measures detailed in the sUAS Operation Manual. The PIC will take

actions including reviewing weather, flight battery requirements, landing and takeoff distances, 

aircraft performance data, and setting the pre-determined safe landing area in case of loss of 

GPS communication before initiation of flight. See Grant of Exemption No. 11671 to Dronair 

Solutions (FAA–2015–0648 page 18)

14 C.F.R. §91.109: Flight instruction; Simulated Instrument Flight and Certain Flight 

Tests.

Section 91.109 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. Remotely piloted aircraft and sUAS, 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. 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. Due to the 

size and speed of the sUAS and the fact that neither a pilot nor passengers will be carried in the 

aircraft, and all persons will be a safe distance away in the event that the UAS experiences any 

difficulties during flight instruction, an equivalent level of safety is provided. The FAA has

granted exemption for the same operation, See Grant of Exemption No. 11671 to Dronair 

Solutions (FAA–2015–0648 page 19)

14 C.F.R. §91.119: General Operating and Flight Rules - 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 sUAS operation at altitudes up to 400 feet AGL, an exemption 

may be needed. In cases where the sUAS is used to survey, inspect, or photograph a structure
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that exceeds 400 feet AGL, the sUAS will not be operated more than 200 feet above the highest 

point of that structure. An exemption was granted by the FAA for like operations - See Grant of 

Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 page 19)

An equivalent level of safety will be achieved given the size, weight, and 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. Compared to flight operations with aircraft or rotorcraft 

operating below 500 feet AGL, weighing far more than the proposed 55 pound maximum, and 

carrying flammable fuel, the sUASs employed by Applicant provide a much safer alternative. In 

addition, the low-altitude operations of the sUAS will ensure safe separation from those of 

conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121: General Operating and Flight Rules - Altimeter settings.

Section 91.121 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. See 

e.g., Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).

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.” For similarly FAA granted exemption, see Grant of Exemption to Alan Purwin 

(Exemption No. 11161). The battery powering the sUAS provides approximately 40 minutes of 

powered flight. Because the 30 minute reserve requirement in 14 C.F.R. §91.151 cannot be met 

by the sUAS, an exemption is needed. With a limited flight time of 30 minutes or 25% battery 

power and line of sight operation in a limited area, an equivalent level of safety is achieved. This 

time/power restriction is more than adequate to safely return the sUAS to its planned landing 

zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Civil Aircraft: Certifications Required

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, it is impractical to carry certification and registration documents or to display them on 

the sUAS. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot in command will have immediate access. The FAA has 

granted exemption for same, See Grant of Exemption No. 11671 to Dronair Solutions (FAA–

2015–0648 page 18)

14 C.F.R. §91.405 (a); §91.407 (a) (1); §91.409 (a) (2); §91.417(a) & (b): Maintenance 

required.
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Sections 91.405(a), 407(a)(1), 409(a)(2), 417(a)(b) 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. Applicant proposes that the maintenance of the 

sUAS will be accomplished by the owner/operator according to the operation manual. As 

provided in the attached manuals, 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 that is 

performed. Moreover, the operator is the person most familiar with the aircraft and is best suited 

to maintain the aircraft in an airworthy condition thereby ensuring an equivalent level of safety. 

See e.g., Grant of Exemption No. 11671 to Dronair Solutions (FAA–2015–0648 page 15)

Privacy

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Filming will be of people who have also consented to being filmed 

or otherwise have agreed to be in the area where filming will take place. 

Public Interest

Applicant is convinced that approval of the exemptions requested in this petition are in the 

public’s interest. Applicants conviction stems from the thorough survey of the applications and 

safety enhancements that sUAS operations offer to a wide variety of existing and future 

markets. Many of the current flight operations that are addressed using manned civil aircraft can 

be performed by small unmanned aircraft systems with reduced environmental impact, lower 

cost, and increased safety. Consider the following comparison between the sUAS and manned 

civil aircraft:

- The sUAS is smaller and weighs considerably less than manned civil aircraft.

o Reduces hazard to property, livestock, and general population.

o The sUAS can operate in smaller areas not possible with large aircraft.

- The sUAS uses batteries rather than combustible fuel.

o Reduces environmental impact by eliminating hydrocarbon emissions.

o Non-flammable power source reduces fire risk.

- The sUAS does not require onboard crew members flying at low altitudes. 

o Reduces risk of injury to flight operations personnel.

Emerging in the marketplace are many applications that are well suited for sUAS 

operations. Applicant has positioned itself to provide professional sUAS services that will benefit 

the public in support of commercial, private, and governmental sectors. Examples of these 

areas may include:

Land Planning and Development Agriculture

Solar Power Power Generation and Distribution

Local Infrastructure & Agencies Environmental Research

Architecture and Engineering Search and Rescue

Although video and photography are main features of sUAS operations, there are a 

multitude of other applications that will come to benefit the public. In addition to providing 

videography/photography for markets like real estate and public/private events, there are others 

that address the needs of far-reaching markets. Examples include:

Closed-Set Filmmaking and Cinematography
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Typically, the motion picture and television industry uses manned airplanes and 

helicopters to carry out aerial filming of subject matter. They are usually large, heavy, and 

powered by combustible fuel. Using a sUAS offers a level of safety that cannot be provided by 

its larger counterparts. The small size, light weight aircraft are powered by batteries giving them 

the advantage to film in more confined areas while reducing risk to structure and persons. 

Closed-Set filming using sUAS is in the interest of the public as it takes place in a controlled 

area, away from spectators and persons not involved in the filming.

Agriculture 

Special lenses fitted to the sUAS camera allow data to be collected from images that 

determine the health of plants growing in a field. That data is used to calculate more precise 

application of pesticide, fertilizer, and water thereby limiting and conserving resources. This can 

ultimately lead to increased crop yield at reduced cost.

Structural Inspection 

Image data collected using a sUAS can be utilized to create 3-dimensional models of 

structures. Engineers can use these 3D models to navigate and make measurements using 

their own in-house CAD software. A considerable advantage is gained in being able to 

determine repair costs and design modifications in office without having to make measurements 

that rely on costly high-risk methods. Engineering firms can benefit by reduced cost and 

enhanced safety.

Environmental Conservation 

Images collected from sUAS flights over areas of interest can be used to create accurate 

maps and models of parks, reserves, and nature conservation areas in an efficient and

affordable way. Rather than collecting data, personnel can spend their time analyzing the maps 

and models for various actions like assessing environmental regulation adherence or creating 

extensive inventories of natural resources.

Accident Scene Reconstruction 

A traffic accident is a good example where the sUAS size and maneuverability can

provide a timely and accurate method of data collection. Following a traffic accident, there is a 

limited amount of time to gather information for use in reconstruction of the event. The sUAS 

can capture ground and aerial imagery to be used in constructing 3-dimensional representations 

of the accident scene. The resulting models can be used at any given time to perform accurate 

measurements and to view every conceivable angle of the scene. The use of sUAS data 

collection provides an immediate response, saves expense, and offers highly accurate output.

Solar Power Land Development 

Development of a potential solar farm site requires a topographic survey to help plan the 

placement of the photovoltaic cells. A sUAS can serve as a valuable data collection tool for 

rendering complex 3-dimensional models of the land under consideration or development. Slope 

angles and height measurements can be made using the image data collected by the sUAS 

cameras. The use of sUAS technology reduces time and cost compared with traditional 

surveying methods while providing increased accuracy and accessibility.

Search and Rescue (SAR) 
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In regard to search and rescue operations, the public stands to benefit from the use of

sUAS technology. The sUAS aircraft are able to perform missions with a high level of complexity 

and, at the same time, require less human operator involvement due to their autonomous 

behavior. Because the search phase in SAR missions is critical to guarantee broad coverage of 

wide areas, the sUAS can execute missions autonomously repeating area coverage multiple 

times when needed. During the rescue phase, the sUAS can be used to deliver medicine, food,

water, etc. to a temporarily non-accessible person or persons.

The applications and services discussed above are only a small sample of a virtually 

limitless set of potential benefits the public, private, and governmental sectors stand to gain. 

Applicant is purposeful in providing safe and valuable services and is convinced that approval of 

the exemptions requested in this petition are, without a doubt, in the public’s interest.

Applicant would like to thank the FAA for considering this request. The Applicant looks

forward to working with the FAA in its determination, and to being part of the discussions as the 

FAA considers how to expand, certify, test, register, track, and control commercial sUAS use in 

the United States.

If you have any questions or need any additional information, please contact the 

undersigned at (310) 880-1474 or at eturn23@me.com.

Respectfully Yours,

Eric C. Turner

Applicant
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APPENDIX A

SUMMARY OF SECTION 333 EXEMPTION REQUEST

Pursuant to C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. Part 21 Subpart H, 14 

C.F.R. Part 36 Subpart A, F & O, 14 C.F.R. §45.23 (b), 14 C.F.R. §61.113 (a) & (b), 14 C.F.R. 

§91.7 (a), 14 C.F.R. §91.9 (b) (2), 14 C.F.R. §91.103(b)(2), 14 C.F.R. §91.109, 14 C.F.R. 

§91.119 (c), 14 C.F.R. §91.121, 14 C.F.R. §91.151 (a), 14 C.F.R. §91.203 (a) & (b), 14 C.F.R. 

§91.405 (a), 14 C.F.R. §91.407 (a) (1), 14 C.F.R. §91.409 (a) (2), 14 C.F.R. §91.417 (a) & (b) to 

operate commercially a small unmanned vehicle (55 lbs. or less) in aerial photography 

operations.

Approval of exemptions allowing commercial operations of sUAS in the aerial 

photography, patrol and inspection, mapping and survey, wildlife and forestry, search and 

rescue, and film industries enhances safety while reducing risk. Conventional manned aircraft 

currently used in these industries creates a greater risk because the aircraft are much larger, 

have combustible fuel, and carry an onboard human crew. In contrast, a sUAS weighing fewer 

than 50 lbs. and powered by batteries eliminates virtually all of that risk, given the reduced mass 

and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of small sUAS, weighing less than 50 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 

21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close 

to the ground, and in a controlled environment and, as a result, are far safer than conventional 

operations conducted with turbine or reciprocating helicopters or full scale manned aircraft 

operating in close proximity to the ground or people.