Private and Confidential

Sean T. Graham (Soaring Services, LLC of Florida) - Section 333 Exemption Petition

U. S. Department of Transportation

&

Federal Aviation Administration (FAA)

11/15/2015

U. S. Department of Transportation, Docket Operations Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave, SE

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b) 

Dear Sir or Madam, Soaring Services, LLC (of Florida), is writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that, Soaring Services, LLC, an owner and business operation of small unmanned 

aircraft, be exempted (for a length as long as possible/authorized) from the Federal Aviation 

Regulations (“FARs”) listed below so that, Soaring Services, LLC, and those working for/under 

the company may operate small ultra-lightweight unmanned aircraft systems (“UAS”) in 

commercially regulated airspace by the Federal Aviation Administration (“FAA”). 

Following exemption and approval by the FAA, Soaring Services, LLC, will primarily use

professionally built DJI Phantom 3 (UAS), DJI Phantom X (UAS), DJI Inspire (UAS), and 

Yuneec Typhoon Q500 (UAS) equipped with cameras for the following applications: Closed-Set 

Film Operations on Film and Television Productions; aerial videography/cinematography to 

safely enhance films and commercials; augmentation of real estate listings pictures and videos;

the creation of visual and topography layout videos for Search and Rescue (SAR) operations 

and other missions for state and local agencies; education; 3D mapping; agricultural 

inspections; and building/construction zone inspections.
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Our, Soaring Services, LLC, exemption request would permit the operation of ultra-lightweight, 

unmanned (i.e. piloted by remote control) UAS’s for the development of community and 

government use videos, permissible within property boundaries for individual homeowners and 

within in tightly controlled, limited airspaces predetermined in areas away from the general 

public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled 

UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. Furthermore, it is my intent to assist future FAA safety protocols 

and regulations exclusive to lightweight UAS's for specific video and photography usage by 

sharing information with the FAA as, Soaring Services, LLC, record flight data and other 

pertinent information gained through permitted flight operations. 

In addition, granting our company’s, Soaring Services, LLC, exemption request will comply 

with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate 

UAS's into the national airspace system, but to “...establish requirements for the safe operation 

of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, 

Search and Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, 

closed-set motion picture film operations and television, structure inspections, and to aid state 

and local agencies. 

Further, Soaring Services, LLC, will conduct operations in compliance with the protocols 

described herein or as otherwise established by the FAA. For the reasons stated below, we,

Soaring Services, LLC, respectfully request the grant of an exemption allowing us to operate 

ultra-lightweight, remote controlled UAS’s to aid academic community awareness, to 

benefit/stimulate attraction to the State of Florida and to enhance personal and public video 

feeds. A grant that will ultimately allow UAS’s to play a more positive role in our local community 

by increasing employment opportunities, heightening security measures and decreasing 

government expenditures by reducing the need for heavier manned aircraft, containing costly, 

combustible fuel- a potential public hazard in and of itself. 
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I. Contact Information:

Sean T. Graham (Soaring Services, LLC)

1275 US Highway 1

P O Box 321

Suite #2

Vero Beach, FL 32960

*P O boxed used due to privacy protection requirements meet*

Phone: 321-446-3998

Email: STG31885@yahoo.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Soaring 

Services, LLC Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

III. The Extent of relief Soaring Services, LLC seeks and the Reason He Seeks Such Relief: 

I, Sean T. Graham (Soaring Services, LLC), submit this application in accordance with the 

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent Soaring Services, LLC contemplated commercial cinematic, academic 

and other flight operations within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our national airspace 

system as it is in the public’s interest to do so. Soaring Services, LLC ultra-lightweight UAS’s 

meet/will meet the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of my ultra-lightweight UAS is expressly contemplated by the Reform 

Act. I would like to operate my ultra-lightweight UAS prior to the time period by which the 

Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct 

experience and valuable information for formal regulation that can be administered uniformly to 

all related UAS aerial video and photography. The Reform Act guides the Secretary in 

determining the types of UAS's that may operate safely in our national airspace system. 

Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether

the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be 

operated by line of sight. 112 P.L. 95 § 333 (a). 
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Each of these items reflect in favor of an exemption for Soaring Services, LLC. Most of my 

UAS’s utilize four (4) rotating propellers for balance, control and stability. Most of my UAS’s are 

equipped with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTL (Return To Launch) 

13) Auto landing technology. 

Each UAS weighs less than the maximum 55 pound limit; including camera(s) with or without 

gimbal (a camera stabilizer). Soaring Services, LLC considers safety as foremost with each 

flight. Our small unmanned aircraft are designed to hover in place, circle in a specific place or 

loiter via GPS and can be operated in high winds; however for safety, stability, and fear of 

financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems

include a GPS mode that allows my UAS to hover/circle in place or land when radio controls 

are released or lost. 

With multiple modes to choose from, Soaring Services, LLC will fly with the modes safest to 

complete the videos for aerial videography/photography and have the ability to choose the 

safest, most reliable and stable mode to prevent accident and hazard. When pilot 

communication from the radio control is lost our UAS’s are designed to slowly descend to the 

point of takeoff and/or to land at point of launch after ascending to a pre-set altitude to ensure 

the UAS will clear any obstacles that may be between the takeoff point and the current position 

of the UAS. The failsafe altitude will not be set more than 200ft and is determined before each 

flight. 
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Soaring Services, LLC will not operate UAS’s near airports, hospitals nor police heliports, and 

will not operate near areas where general public is within fifty to one hundred (50-100) yards 

depending on location, conditions and weather. I will be constantly on alert for any manned 

aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest 

and safest ground point should a manned aircraft approach my location or I suspect a manned 

aircraft may approach near my location. Our UAS’s are capable of vertical and horizontal 

operations, and are flown within the pilots line of sight. Our UAS’s are also flown with a second 

operator who aids in watching for any obstacles, including manned aircraft, within the flight zone 

of the UAS. Utilizing battery power rather than combustible fuels, flights generally last from ten

(10) to twenty (20) minutes, with an altitude under two-hundred (200) feet. Smart Mode 

includes, position hold, self-leveling, altitude command, GPS, return home feature, and safety 

control to return home or land in the event of communication interruption between RC 

transmitter and UAS.

Soaring Services, LLC will utilize a fresh fully charged battery with each flight as a safety 

precaution. We will not operate our UAS’s at or below manufacturer recommend minimum 

charge levels for operation; preferring to remain well within a safe operating range to insure 

adequate communication between radio control and UAS’s to eliminate potential for crash, loss 

of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for 

sufficient safe level of operation. We (I) do not believe in taking risk that may cause a crash thus 

creating a potential hazard to the public/property/manned aircraft. In addition, I do not want to 

lose our (my) investments (UAV’s). Our pilot(s) and I have clocked numerous practice flights in 

remote areas as a hobbyist simulating flights for future commercial use to gain familiarization

with the characteristics of these specific UAS's performances under different temperature and 

weather conditions. This will also be completed for all future purchases of UAV’s prior to utilizing 

for commercial purposes. We (I) have practiced computerized simulated flights to maintain 

adequate skills and response reflex time. All for the sake of safety. 

We, Soaring Services, LLC, will be extremely cautious when operating UAS’s/ultralightweight unmanned aircraft’s and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls 

well within Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. Soaring Services, 

LLC UAS’s will demonstrate an excellent safety record prior to flight so as not to pose any 

threat to the general public or national security. 

IV. How Soaring Services, LLC Request Will Benefit the Public As A Whole: Aerial 

videography for geographical awareness, education, search and rescue, land management, 

structure inspections, and for real estate marketing have all been around for a long time via

manned fixed wing aircraft and helicopters. For small budget companies, average homeowners,

and property owners the expense of such aerial videography is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford to absorb such expense; 

depriving non-luxury owners and lower budget companies from a valuable marketing tool. 

Manned aircraft pose a threat to the public through a potential catastrophic crash that 
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communities have experienced in the past with military aircraft, medical helicopters, and news 

helicopters crashes. Each resulting in loss of life. 

Each with combustible fuel that exploded and burned on impact. Police helicopters have made 

emergency hard landings. Soaring Services, LLC UAS’s pose no such threat since size and 

lack of combustible fuel alleviates any potential threat to the public. Congress has already 

proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the 

national airspace system, hence the passing of the Reform Act. Granting Soaring Services, 

LLC exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits in and around the area. Our ultra-lightweight UAS’s are all battery 

powered and create no emissions that can harm the environment. The consequence of our

ultra-lightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which 

are heavy, contain combustible fuel, and can cause catastrophic devastation to the public. The 

public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated ultra-lightweight UAS's. Permitting us Soaring 

Services, LLC to immediately fly within national air space furthers economic growth. Granting 

our exemption request substantially furthers the economic impact of my area and the

surrounding community for companies looking to relocate or build around my area as well as 

individuals looking to relocate for career advancement through academic and geographical 

awareness. Both of which serve as a stimulus to the community. 

V. Reasons Why Soaring Services, LLC Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: Our,

Soaring Services, LLC exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting Soaring Services, LLC to log more flight time in FAA controlled 

airspace, with communication with the FAA, will allow us to contribute to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land,

and structured owners. For development in cooperation with the FAA. In addition Soaring 

Services, LLC submit the following representations of enhancements to current aerial

videography and photography: Our UAS’s total weight is less than the maximum 55 pound limit.

We only operate our UAS’s below 200 feet (well within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012); Our UAS’s only operate for 3-25 minutes per 

flight; we land our UAS’s prior to manufacturer recommended minimum level of battery power; 

we pilot our UAS’s through remote control only by line of sight; and have live video feed for

monitoring video recording; we receive a live telemetry feed from our UAS’s during all flights 

which include remaining battery voltage, distance, altitude, and any anomalies that may occur 

during flight.

Our UAS’s Command and Control utilize 5.8 GHz for its control frequency in accordance 

with CFR 47, Part 15 for model aircraft use.

Our UAS’s camera system utilizes 2.4 GHz to supply the video feed in accordance with CFR 

47, Part 15.

Our UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers and 

then lands at the GPS takeoff point if communication with the remote control pilot 
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is lost; we actively record and analyze flight data through the flight controller application(s) to 

constantly update and enhance safety protocols; we only operate in reasonably safe 

environments; we conduct extensive preflight inspections and protocol, during which safety 

carries primary importance; we always obtain all necessary permissions prior to operation; and, 

we have procedures in place to abort flights in the event of safety breaches or potential danger.

Soaring Services, LLC safety protocols provide a level of safety equal to or exceeding existing 

rules. It is important to note that absent the integration of commercial UAS’s into our national 

airspace system, helicopters are the primary means of aerial video and photography for 

community awareness real estate, structured inspections, land management and search and 

rescue. While the safety record of such helicopters is remarkably astounding, there has been

incidents involving loss of life as well as extensive property damage; it is far safer to operate a 

battery powered ultra-lightweight UAS. First, the potential loss of life is diminished because 

UAS's carry no people on board and we only operate our UAS’s in specific areas away from 

mass populations. Second, there is no fuel on board our UAS’s and thus the potential for fire or 

explosions is greatly diminished. Third, the small size and extreme maneuverability of our UAS’s 

allow us to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small 

size and weight, even when close enough to capture amazing images, our UAS’s need not be 

so close to the objects they are focused on through the technology and use of post editing 

software allowing pan and zoom. Accordingly, our UAS’s has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The 

size, weight and enclosed operational area of our, Soaring Services, LLC, UAS’s permits 

exemption from Part 21 because our UAS’s meet (and exceed) an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. Our, Soaring Services, LLC, 

current and projected UAS's meet/will meet or exceed each of the elements.

14 C.F.R. 91.7(a) 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 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas of where safety can be defined. 
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The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS’s utilize

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by 

Soaring Services, LLC. 

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. Our UAS’s can be marked with the 

appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. Soaring Services, 

LLC members (employees and/or contractors) who are the PIC will possess at least a sport pilot 

certificate and a driver's license. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 

C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for 

the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. My UAS will never operate at an altitude greater than 300fclose AGL; safely below 

the standard of 400 AGL. Soaring Services, LLC will operate our UAS’s in safe areas away 

from public and traffic, providing a level of safety at least equivalent to or below those in relation 

to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS’s, an 

equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2,

Manual

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] 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. . . .”These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to our, Soaring Services, LLC UAS’s. 

However, as a safety precaution we inspect our UAS’s before and after each flight. If this 

regulation should be required in the future then we will abide by set regulations.

A Summary; The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled 
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Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area 

of my UAS permits exemption from Part 21 because our, Soaring Services, LLC, UAS’s meet 

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized 

to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. Our

UAS’s meet or exceed each of the elements. 14 C.F.R. 91.7(a) 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 (b) (2) requires an 

aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of 

the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program 

that involves regular software updates and curative measures for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved. In summary, Soaring Services, LLC, 

seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 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); 14 C.F.R. § 91.109; 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. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 

91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially 

operate our, Soaring Services, LLC, small unmanned vehicle/lightweight unmanned aircraft 

vehicles in community awareness, education, structural inspection land management, search 

and rescue and real estate operations, and to develop economic platforms for the 

aforementioned to enhance the experience of those seeking to relocate, 

rebuild, reevaluate and to find in our areas.

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply:

1. The UAS must weigh less than 55 pounds (25kg), including energy source(s) 

and equipment

2. The UAS may not be flown at a speed exceeding a ground speed of 85 knots.
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3. Flights must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All 

altitudes reported to ATC must be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC's state driver’s license.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO 

and PIC must be able to communicate verbally at all times.

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere 

in this operations manual, the conditions and limitations herein take precedence and 

must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight in accordance with the operator's manual. The PIC who conducts 

the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in the operator's manual. At a minimum, 

the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller 
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f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot 

certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multirotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS 

to be utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing 

currency flights can be conducted under this grant of exemption to accomplish the required 

flight time and 90 day currency. During training, proficiency, experience-building, and take-off 

and landing currency flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants 

in accordance with 14 CFR § 91.119.
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13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical 

test standards that support a jurisdictional FAA FSDO evaluation and approval of company 

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface 

in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons 

must be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is 

necessary for reductions to the distances specified in the petitioner’s manuals. This is 

consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 

Issue a Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet 

if it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of 

the filming production area to note terrain features, obstructions, buildings, safety barriers, 
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etc. Such barriers may protect non-participating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 

8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UAS

must return to a pre-determined location within the security perimeter and land or be 

recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.
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27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction 

over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming 

production under this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation 

of the UAS.

d. Make, model and serial or N-number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming 

production event 

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the filming production event; the 

list of those who gave permission must be made available to the 

inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and the 

altitudes essential to accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC 

at the ground control station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

30. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.
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32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS may 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.

34. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may 

not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting our, 

Soaring Services, LLC, requests for exemption will reduce current risk levels and thereby 

enhance safety. Our UAS’s craft do not contain potentially explosive fuel, is smaller, lighter and 

more maneuverable than conventional video and photographic aircraft with much less flight 

time. Further, we operate at lower altitudes and in controlled airspace eliminating potential 

public risk flying to and from established airfields. We, Soaring Services, LLC, have been 

informally analyzing and recording flight information and will compile safety protocols and the 

implementation of a flight operations manual for usage that exceeds currently accepted means 

and methods for safe flight. Formal collection of information shared with the FAA will enhance 

the FAA's internal efforts to establish protocols for complying with the FAA Modernization and 

Reform Act of 2012. There are no personnel on board our, Soaring Services, LLC, UAS’s and 

therefore the likelihood of death or serious bodily injury is significantly diminished. Our, Soaring 

Services, LLC, operation of UAS’s, weighing less than forty (40) pounds and traveling at lower 

speeds within limited areas low to the ground will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly We, Soaring Services, LLC, respectfully request 

that the FAA grant our exemption requests and we are willing to cooperate in sharing 

information to benefit the FAA, safety of manned aircraft, and the general public at large. 
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Respectfully submitted, 

Sean T. Graham (Soaring Services, LLC)

1275 US Highway 1

P O Box 321

Suite #2

Vero Beach, FL 32960

Phone: 321-446-3998

Email: STG31885@yahoo.com
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Soaring Services, LLC

1275 US Highway 1

P O Box 321

Suite #2

Vero Beach, FL 32960

Phone: 321-446-3998

Email: STG31885@yahoo.com

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. Pre-Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic.

Contact respective airport to advice of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewer’s optional point of control for best visual site of UAS 

while in flight 

Emergency landing areas 

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 
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If in a subdivision or area that is within 150 feet of a residential street, post warning 

Sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain Back 150 Feet " 

Flight Protocol: takeoff and land from same location (have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to 

minimal elevation sufficient to acquire desired results remained prepared for emergency landing 

at all times pay attention to flight time – warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. a) Disconnect battery to prevent accidental activation of propulsion system 

2. b) Secure UAS in a safe location 

 c) Remove all warning signs from public access areas Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight 

Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining the future UAS’s safety 

protocols are imperative. 
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Date:____________________Location:____________________________________________

Pre-flight Inspection: 

o Yes o No 

Comment: _________________________________________________ 

Elements 

Proximity to airport: _________________ (see attached map pinpointing approximate location 

of flight) 

Airport notified: No Yes 

Date:_______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

______________________________________________________________ 

Proximity to medium traffic road: 

_________________________________________________________ 

Proximity to heavily traveled roadway road: 

_________________________________________________ 

Proximity to congested population: 

________________________________________________________ 

Approx. Takeoff Time : GMT: 

Weather Good Fair Poor Comment : 

Visibility Good Fair Poor Comment : 

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment : 

Approx. Landing Time: GMT: Estimated Elevation Ground level: 

Safety Concerns: 

Additional Comments:

Sea level: 
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Aircraft Manuals

Please see UAS’s manufacturer's user manuals, maintenance instructions, and illustrated 

parts catalogs. All of which are available online and can also be provided directly to the FAA 

upon request from Soaring Services, LLC along with any other information required.

1. DJI Phantom 3 (UAS)

2. DJI Phantom X (UAS)

3. DJI Inspire (UAS)

4. Yuneec Typhoon Q500 (UAS)

- Registration pending

Soaring Services, LLC will make sure any UAV’s used for our business are registered. In the 

event that future UAV(s) in addition to the above are purchased for use by the company, the 

FAA will be notified and the UAV(s) will then be registered.

Thank you for your time and consideration in this matter.

For more information or questions please contact:

Soaring Services, LLC

1275 US Highway 1

P O Box 321

Suite #2

Vero Beach, FL 32960

*P O boxed used due to privacy protection requirements meet*

Phone: 321-446-3998

Email: STG31885@yahoo.com