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March 8, 2016

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT

Dear Sir/Madam:

This petition is being submitted on our own behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization & Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R., Part 11, Giant Model Products, LLC, ("GMP"), a Missouri based limited liability 

company operating a Small Unmanned Aircraft System ("sUAS") with Gerry Hinshaw as the PIC, 

equipped to conduct aerial photography, videography, and survey for various industries, hereby 

applies for an exemption from the Federal Aviation Regulations ("FARs") listed below to allow 

operation of our sUAS commercially in airspace regulated by the Federal Aviation

Administration ("FAA") so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit GMP to pursue its commercial interests in providing 

services to consumers interested aerial data capture using a small advanced sUAS in the 

following areas:

 Agricultural Surveying

 Aerial video/photography or providing live video feed

 Closed Set Film Cinematography

 Real Estate Photography

 Product Demonstrations

 Research & Development

GMP states that all sUAS flights that will occur over private or controlled access property will do 

so with the property owner's prior consent and knowledge and that only people who have 

consented or otherwise have agreed to be in the area where photography and videography will 

take place will be captured.
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GMP understands the proper roles of an observer, communication procedures, proper visual 

scan techniques, operations at non-towered airports, and appropriate sections of the 

Aeronautical Information Manual.

I, Gerry Hinshaw, have flown small multi-rotors for over four years, with over 10000 hours of 

flight time.

Contact Information:

Company: Giant Model Products, LLC

Name: Gerry Hinshaw

Address: 3972 NE Breckenridge Court, Lathrop, MO 64465

Email: President@GiantModelProducts.com

Cell phone: 816-284-3634

GMP has instilled safety protocols and controls to avoid and prevent public hazard, as well as 

manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to 

lightweight UAS's specific to video and photography usage, as GMP will record flight data and 

other information gained through permitted flight operations to share with the FAA through 

any required FAA reports to assist with future protocol and safety regulation. This data can be 

logged with the DJI Pilot App.

Regulations from which the exemption is requested:

14 C.F.R. Part 21

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. 91.119

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. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

UNMANNED AIRCRAFT SYSTEM

We are petitioning for exemption to enable GMP to operate a Tarot S810Pro, DJI 45O, X8 

airplane, RMRC Penguin, RMRC Air Titan, equipped with three axis gimbaled camera. These 

sUAS all weigh less than 25 pounds, have a 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, including a no fly zone feature. These sUAS named above operate in 

the 2.4 - 5.8 GHz frequency range, which complies with FCC regulations. Each system also has 

the failsafe function of the autopilot system, which means when the communication between 

the Main Controller and the transmitter is lost, the system will automatically trigger Return To 

Home and will land safely.
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The above specifications meet standards listed below, some derived in accordance with the 

Model Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and 

will operate at sites that are a "sufficient distance" from populated areas within the 

sterile area described in the operators manual. Such operations will insure that the sUAS 

will "not create a hazard to users of the national airspace system or the public".

 When flying sUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft.

 Maximum flight time for each operational flight will be 60 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 

60 minute limit.

 The sUAS will be programmed so that it will not be operated at an altitude of no more 

than 400 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned.

 The sUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal).

 The sUAS will operate at speeds of no more than 55 knots.

 Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

GMP requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of the sUAS System:

14 C.F.R. Part 21: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the Tarot 810 Pro, DJI 450, and said airplanes 

under either or all of the following provisions: 

21.191: Experimental Certificates

Experimental certificates are issued for the following purposes:

(a) Research & Development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with function and reliability requirements of the regulations. Since 

the experimental certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental certificate 

would permit our commercial purpose as well. The aircraft will not carry persons or property, 

will not carry fuel, and will only fly under strict operational requirements. Combined with the 

UA's light weight, being constructed primarily of foam, carbon fiber, and/or plastic, we propose 
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that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 14 C.F.R. Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of safety 

outlined in the previous paragraph.

14 C.F.R. 45.23: Display of Marks, General and 45.29 Size of Marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on 

the top of the aircraft, as shown above, where the PIC, VO, and others in the vicinity of the 

aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information at the ground station. Finally, we will display at the ground station a 

high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in 

letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 

station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin. 

14 C.F.R.  61.113: Private Pilot Privileges & Limitations: PIC.

Pursuant to 14 C.F.R.  61.113 (a) & (b) private pilots are limited to non-commercial operations. 

Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks 

attended to the operation of my UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 C. F. R.  61, et seq. Thus, allowing GMP to operate my UAS to meet and 

exceed current safety levels in relation to 14 C.F.R.  61.113 (a) & (b).

14 C.F.R. 91.7: Prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this regulation is 

inapplicable.

14 C.F.R. 91.9: Civil aircraft flight manual, marking, and placard requirements. This regulation 

provides that no person may operate an aircraft unless a current approved flight manual is in 

the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to 

this requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew during flight operations. To obtain an

equivalent level of safety and meet the intent of the 91.9, we propose that a current, approved 

sUAS Flight Manual but be available to the crew at the ground station anytime the aircraft is in, 

or preparing for, flight.

14 C.F.R. 91.119: Minimum Safe Altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS 

would be photography or survey of persons, vessels, vehicles, or structures, it would be 

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over 
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property or persons where permission has been obtained and careful pre-planning has been 

performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UAS, the hazard to persons, vehicles, and structures is 

minimal compared to manned aircraft, which should be considered in granting the exception.

14 C.F.R. 91.121: Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 600 

feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other 

aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the sUAS on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout.

14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at last 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and the 

maximum duration of flight from a single battery charge is 12-45 minutes (depending on which 

sUAS) with a 20% reserve. Since the aircraft will never fly more than 1/2NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 

minute reserve and ask that our reserve will be to fly the mission to the point of intended 

landing and have at least a 20% battery reserve after that. 

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

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew". With all of our vehicles at a 

maximum gross weight of 7 pounds, the sUAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed appropriate 

for this aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certificates be permanently affixed to the 

aircraft via placard containing the following information, plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 C.F.R. 45.23.

14 C.F.R. Subpart E (91.401-91.417): Maintenance, Preventative Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7 after maintenance and inspection. It is our intention that the PIC perform maintenance 

and inspection of the aircraft and "be authorized to approve the aircraft for return to service". 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 
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addition, conduct detailed inspections after every two hours of flight. Maintenance performed 

by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. The PIC 

will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

RE: Exemption Request Section 333 of the FAA Reform Act

Thank you for the opportunity to give examples as to why granting Giant Model Products, LLC, 

the requested exemption would be in the public interest, and how it would benefit the public as 

a whole. Please find the following examples supporting this exemption:

1. UAS use as an alternative to large, manned aircraft using combustible fuel in cinema. 

The UAS, powered by batteries, is smaller, lighter, and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board, and will 

thereby reduce current risk levels to both the pilots aboard and people below, thereby 

enhancing safety and drastically diminishing the likelihood of death or serious bodily injury. The 

small weight and minimal payload allows for high quality aerial video at safety levels before 

unseen.

2. Public Good: Closed Set Cinematography

GMP can offer the same aerial videography a production is requesting without any of the 

danger associated with a traditional full sized manned helicopter using combustible fuel when 

flying over a set. GPS stabilized stationary angles and low altitudes, predictable flight paths with 

full coordination between people on the ground without need for complicated communication 

systems, and the ability to land safely in a comparably smaller area to a full sized aircraft all 

increase safety and public good. The costs of the production are drastically lowered and safety 

is raised. High quality aerial cinematography becomes accessible to smaller productions, 

facilitating market growth and public job creation.

3. UAS use in Aerial Photography

UAS use in photography creates dramatic versatility never before possible. The impact of this 

versatility creates immediate value to small and large businesses, charity organizations, and 

private citizens. Small businesses would never have access to the production value of an aerial 

photo without great expense, usually reserved for larger corporations. Having access to this for 

promotion needs is a large benefit to businesses. 

We respectfully request exemption under Section 333 to enable Giant Model Products, LLC, to 

operate safe, low risk commercial sUAS operations for the activities stated. GMP at all times will 

respect the space and privacy of citizens and property, whilst keeping our skies safe.

Sincerely,

Gerry Hinshaw, Owner/Director

Giant Model Products, LLC

President@GiantModelProducts.com

www.giantmodelproducts.com