SUMMARY:

Proto Multimedia LLC of Amherst, NH requests an exemption from FAA Modernization and Reform Act of 

2012, Public Law 112-95 FEB. 14, 2012, Section 333. This exemption is necessary to conduct photography 

and videography contract work for small businesses via Unmanned Aerial Vehicle (UAV). The nature of the 

UAV use would be exclusively to publish a product for clients, and in accordance with all local and federal 

regulations.

Dear FAA Representative,

I am writing on behalf of Proto Multimedia LLC of Amherst, NH to request an exemption from FAA 

Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333. 

This exemption is necessary to conduct photography and videography contract work for small businesses 

via Unmanned Aerial Vehicle (UAV)—a 3DRobotics Solo, described here: 

https://store.3drobotics.com/products/solo?taxon_id=66. Because the use is commercial in nature, an 

exemption is required to offer portraits, event videography, and other shots that abide by local and 

federal law. I seek relief with this exemption for the maximum two years allowable, with plans to extend 

the exemption should the business require it.

This request would benefit several small businesses and individuals in the New England area by offering 

low-cost aerial video for individuals or organizations who require it. The demand for this type of 

videography is increasing, and Proto Multimedia LLC seeks to meet that demand as it can.

The FAA’s granting of this exemption would not adversely affect safety, as the UAV will be operated in 

accordance with all FAA requirements for the March 23, 2015 COA on the matter. The operational height 

of the UAV will not exceed 200 feet in altitude. The UAV will be operated within line-of-sight at all times. 

It will not be operated within protected airspace, or within 5 miles of an airport. The UAV will not be 

operated in inclement weather, high winds, or reduced visibility. It will not be operated by a person 

impaired by alcohol or illegal drugs. The UAV will not be used near sensitive infrastructure or property. 

I have researched the local laws of New Hampshire pertaining to drone videography, and as my targeted 

services do not include aerial videography of domiciles, neighborhoods, or cities, no additional steps are 

needed. However, I will comply with all local laws if a client requests services in another state. At this 

time, I do not require international use of the privileges of a potential exemption.

I believe to have sufficient cause to request an exemption as the nature of my UAV use would be 

exclusively to publish a product for clients. It will not be used for espionage, invasion of privacy, or any 

other potential violation of another’s rights. The model I intend to use has extreme safety features 

including LiDAR, a parachute, GPS, and computer-controlled stabilization, making it one of the safest UAVs 

currently available to anyone. Risk of accidental collisions is extremely low, and in the event of a 

catastrophic systems failure, the parachute will slow the descent to prevent damage or injury to anything 

underneath.

Sincerely,

Christian Thomas 

President of Proto Multimedia LLC