October 30, 2015

Docket Management Facility 

US Department of Transportation

1200 New Jersey Avenue

SE West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Shane Floyd Films LLC Request for Exemption Request from the Requirements of Title 14 

of the Code of Federal Regulations Sections:

• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates,

• 14 C.F.R. §91.203 (a) (1), 

• 14 C.F.R. § 45.23 (b). Marking of the Aircraft, 

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

14 C.F.R. §91.7(a): Civil aircraft airworthiness, 

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft, 

• 14 C.F.R. § 91.103: Preflight action, 

• 14 C.F.R. §91.109: Flight instruction, 

• 14 C.F.R. §91.119: Minimum safe altitudes, 14 C.F.R. §91.121 Altimeter Settings, 14 

C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions, 

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration, 

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

Shane Floyd Films LLC

Shane Floyd

P.O. Box 98563

Lubbock Texas 79499

Phone (806) 544-0147

Email: shanetelevision2000@gmail.com
Table of Contents

I. The Applicable Legal Standard Under Section 333

II. Airworthiness of the Inspire 1

III. Mandatory Operating Conditions

IV. Training & Operator Requirements

V. Requested Exemptions and Equivalent Level of Safety

• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

• 14 C.F.R. § 45.23 (b). Marking of the Aircraft

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

Command.

• 14 C.F.R. §91.7(a): Civil aircraft airworthiness.

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

• 14 C.F.R. § 91.103: Preflight action

• 14 C.F.R. §91.109: Flight instruction

• 14 C.F.R. §91.119: Minimum safe altitudes

• 14 C.F.R. §91.121 Altimeter Settings

• 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

VI. Privacy and Public Interest

VII. Summary for Federal Register

VII. Closing

Additional Documentation:

• Flight Planning Document (Appendix A)

• Inspire 1 UAS Operations Manual (Appendix B)

• Inspire 1 UAS Maintenance Manual (Appendix C)
October 30, 2015 

Docket Management Facility

US Department of Transportation 

1200 New Jersey Avenue 

SE West Building Ground Floor Room W12-140 

Washington, DC 20590 

Exemption Request under Section 333

Dear Sir or Madam:

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

14 C.F.R. Part 11, Shane Floyd Films LLC (“Applicant”) seeks an exemption from Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its Unmanned Aircraft System 

(“UAS”), the DJI Inspire 1 (“Inspire 1”) equipped to conduct aerial photography and 

videography for the motion picture and television industry for scripted closed set filming 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.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described Inspire 1 to support aerial photography and 

videography for use in the motion picture and television industry for scripted closed set filming. 

The UA, 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 and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 30

minutes, this is offers little or no risk to national security.

The name and contact information of the applicant are: 

Shane Floyd Films LLC

Shane Floyd

P.O. Box 98563

Lubbock Texas 79499

Phone (806) 544-0147

Email: shanetelevision2000@gmail.com

The regulations from which the exemption is requested are listed below:
• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

• 14 C.F.R. § 45.23 (b). Marking of the Aircraft

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

Command.

• 14 C.F.R. §91.7(a): Civil aircraft airworthiness.

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

• 14 C.F.R. § 91.103: Preflight action

• 14 C.F.R. §91.109: Flight instruction

• 14 C.F.R. §91.119: Minimum safe altitudes

• 14 C.F.R. §91.121 Altimeter Settings

• 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

The Applicable Legal Standard Under Section 333

Shane Floyd Films LLC submits that grant of this exemption application for use of the Inspire 1

in aerial photography and videography for the motion picture and television industry for 

scripted closed set filming will advance the Congressional mandate in Section 333 of the

Reform Act to accelerate the introduction of UASs into the national airspace system (“NAS”) if

it can be accomplished safely. This law directs the Secretary of Transportation to consider

whether certain UASs may operate safely in the NAS before completion of the rulemaking

required under Section 332 of the Reform Act. In making this determination, the Secretary is

required to determine which types of UASs do not create a hazard to users of the NAS or the

public or pose a threat to national security in light of the following:

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

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

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

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation of

such aircraft in the national airspace system.” Id. §333(c). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:
The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716

of this title if the Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as

amended; the strong equivalent level of safety surrounding the proposed operations; and the

significant public benefit, including enhanced safety and cost savings associated with

transitioning to UASs for aerial survey photography. Accordingly, the applicant respectfully

requests that the FAA grant the requested exemption without delay.

II. Airworthiness of the Inspire 1

The UAS includes an Unmanned Aircraft (UA) and ground station-based equipment and crew: 

The Unmanned Aircraft System (UA): 

• The Inspire 1 is a lightweight (2935 g gross weight with all on-board equipment and 

battery), battery operated 4-motor rotorcraft in the form of a quadcopter that takes off 

and lands vertically, manufactured by DJI, the Inspire 1 Model T600.

• An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller.

• An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video. 

• An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site. 

• A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the onboard camera plus all the flight data from the telemetry system described above;

The Ground Station-Based Part of the System:

• A Pilot in Command (PIC) in operational control of a flight operation from beginning 

to end and who controls the UA while in the air. 

• A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA 

while in flight.

• A radio receiver receiving live video and flight data from the on-board camera and 

computer projects it all together onto a screen for the PIC to view during flight.

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually 

track the UA while in flight.
II. Mandatory Operating Conditions

Grant of the exemption to Shane Floyd Films LLC will be subject to the following mandatory 

conditions which are based upon operating conditions set forth in accordance with FAA Policy N 

8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:

• The Inspire 1 will be operated in the field with both a pilot-in-command (“PIC”) and a 

visual observer (“VO”)

• No flight will be made with a UA gross weight exceeding 55 pounds;

• All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an 

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC

• All operations must utilize a VO. The VO and PIC must be able to communicate by voice 

at all times during a flight operation;

• Operations will be restricted to flights over private property with the permission of the 

property owner;

• The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot 

and at least ten hours logged as a UA pilot with a similar UA type;

• All required permits will be obtained from state and local government prior to operation;

• The Inspire 1 will not be operated over densely populated areas;

• The Inspire 1 will not be operated at air shows;

• The Inspire 1 will not be operated over any open-air assembly of people;

• The Inspire 1 will not be operated over heavily trafficked roads;

• The Inspire 1 will not be operated within 5 NM of an airport or heliport;

• The Inspire 1 will not be operated over properties smaller than two acres in size;

• Operations will be restricted to day only and weather conditions equivalent to VFR;

• The PIC will brief the VO and property owner about the operation and risk before the 

first flight at each new location;

• No flight may be made without a Pre-Flight Inspection by the PIC before each operation

III. Training and Operator Requirements

The Inspire 1 will be operated by a contracted pilot with a private pilots certificate. The airspace 

in which the Inspire 1 will operate will be disclosed to the FAA in advance.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training. 

The combination of the UA's small size, light weight, flight performance and ability, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, and under 

all of the Restrictions (a) through (o) listed above, the FAA can have full confidence that the 
operation will have an equivalent or greater level of safety than manned aircraft performing the 

same mission. 

As described more fully below, the requested exemption would authorize commercial operations 

of aerial surveys using the Inspire 1, which at 6.47 lbs., is small in size. The Inspire 1 will be 

operated under controlled conditions at low altitude in airspace that is limited in scope, as 

described more fully herein. 

IV. Requested Exemptions and Equivalent Level of Safety

14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

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 UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS 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 UAS to be operated hereunder 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 area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the 

Manual’s requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.
14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires that 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.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. 

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 UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAS will see the 

identification of the UAS as “Experimental.” 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.

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167A.

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s 

license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing 

on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Manual. 

The level of safety provided by the requirements included in the Manual exceeds that provided 

by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the operation of the UAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the UAS as requested with a private pilot as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 
exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance and 

use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent 

level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) 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 UAS, given its size and configuration has no ability or 

place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but 

because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

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

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. An equivalent level of safety will be provided as set forth in 

Sections J and K of the Manual. The PIC will take all actions including reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 C.F.R. §91.109: Flight instruction

Section 91.103 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.

UAS and remotely piloted aircraft, 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 communications. 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. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the

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

the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The regulation stats that 

over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, 
vessel, vehicle, or structure. Since the UAS will be operating at a maximum of 400 ft AGL, we 

cannot comply with this requirement.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. The UAV will never operate at higher than 400 AGL. The 

UAS will be operated in a restricted area with security perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent. No flight will be taken 

without the permission of the property owner or local officials. The property owner or local 

officials will be briefed on the expected flight path and the associated risks to persons and 

property on the ground. The UAV 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. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 

55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 

AGL in the movie industry. In addition, the low-altitude operations of the UAS will ensure 

separation between these small-UAS operations and the operations of conventional aircraft that 

must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation 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.” Since, the UAS does not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be needed. The regulation also 

requires that the aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft.

The UAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An AGL altimeter measurement above the takeoff 

point is transmitted via radio from the UAS on-board computer to the display screen held by the 

PIC providing a constantly updated AGL readout. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight.

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.”

The battery powering the UAS provides approximately 40 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to 
approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its limited operating 

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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." 

At a maximum gross weight of 6.47 pounds, the UAV 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. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the pilot flying the UAS will have immediate 

access to them, to the extent they are applicable to the UAS. 

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 CFR 

45.23, which follows immediately after the proposed placard description below: 

EXPERIMENTAL 

Manufacturer: DJI Innovations, Inc. 

Model: Inspire 1

Serial Number: W13DCH19040647

If found please contact: (806) 544-0147 
The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator or owner 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. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. It is our intention that the PIC preforms maintenance and 

inspection of the aircraft pursuant to the flight manual and operating handbook as referenced in 

the Manual and “be authorized to approve the aircraft for return to service.” Moreover, the PIC is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in 

an airworthy condition prior to every flight and in addition, conduct detailed inspections after 

every two hours of flight. Maintenance performed by the PIC is limited to repairing small 

cracks, replacing propellers, checking electrical connections and updating software and firmware 

for the on-board computer. The manufacturer or their designated repair facility shall perform all 

other maintenance. 

An equivalent level of safety will be achieved because this small UAS is very limited in size and 

carries a small payload and operates only in restricted areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 

400 feet AGL. As provided in the Appendix A, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed in accordance with 91.417.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or observer.

The UAS maximum gross weight is 6.47 pounds, it is constructed of carbon fiber and plastic and 

the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely 

event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the

UA will return autonomously to the site of launching and land without crew intervention.

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial

pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to

20/20 and a valid state issued driver's license. The 20/20 vision requirement will ensure that the
PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a 

much larger vehicle.

V. Privacy and Public Interest

The public’s best interest is achieved by the safe integration and operation of UAS into the 

national air space. With the ongoing exemption process, the FAA has to identify those exemption 

requests with the public’s best interest in mind and select the companies who will be able to 

achieve this in a safe and responsible manner. The main problems the public has with UAS are 

the fear of what they will be used for and whether or not they pose a safety hazard when shared 

with commercial airspace. One of the main concerns the public has with the integration of UAS 

into national air space is protection of privacy. The media has also placed a negative light on 

UAS when it comes to privacy sharing only stories of how the military has used this technology 

for surveillance and how un-responsible UAV pilots have invaded FAA airspace and threatened 

the safety of aircraft. 

In order to assure the public of Shane Floyd Films LLC’s assurance of 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. 

Shane Floyd Films LLC is more than willing to help with public assurance and education and 

that safe UAV operations starts with conducting flight operations within strict operating 

environments to protect the safety and privacy of the public. 

The experience we have built from UAS operations, manned flight operations and training and 

aircraft maintenance; the FAA will provide a great service to the American public by approving 

our exemption request herein. Shane Floyd Films LLC will provide any additional information 

requested and will diligently work with the FAA to make this approval a reality as it is in the 

best interest and safety of the public as directed by Congress.

VI. Summary for Federal Register

Shane Floyd Films LLC hereby submits, pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the Inspire 1 unmanned aircraft to conduct aerial 

photography and videography for the motion picture and television industry for scripted closed 

set filming. An exemption is requested from the following regulations:

• 14 C.F.R. § Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

• 14 C.F.R. § 45.23 (b). Marking of the Aircraft

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

Command.

• 14 C.F.R. §91.7(a): Civil aircraft airworthiness.

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

• 14 C.F.R. § 91.103: Preflight action
• 14 C.F.R. §91.109: Flight instruction

• 14 C.F.R. §91.119: Minimum safe altitudes

• 14 C.F.R. §91.121 Altimeter Settings

• 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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

• 8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical

VII. Closing

Shane Floyd Films LLC respectfully submits that because this small, unmanned aerial vehicle 

will be used in lieu of comparatively hazardous operations now conducted with fixed wing and 

rotary conventional aircraft, the FAA can have confidence that the operations will achieve at 

least an equivalent level or greater level of safety. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe 

operation of such aircraft systems in the national airspace system.”

Shane Floyd Films LLC is prepared to modify or amend any part of this request to satisfy the 

FAA’s need for an equivalent level of safety. Please contact us at any time if you require 

additional information or clarification. We look forward to working with your office.

Regards,

Shane Floyd, Owner 

Shane Floyd Films LLC
APPENDIXA–FLIGHT MANUAL

FLIGHT RESTRICTIONS

(a) No flight will be made with a UA Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400'AGL, at an airspeed of 

no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate 

verbally at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the property 

owner;

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten 

hours logged as a UA pilot with a similar UA type;

(f) All required permits will be obtained from state and local government prior to operation;

(g) The UAC System will not be operated over densely populated areas;

(h) The UAV System will not be operated at air shows;

(i) The UAV System will not be operated over any open-air assembly of people;

(j)The UAV System will not be operated over heavily trafficked roads;

(k) The UAV System will not be operated within 5 NM of an airport or heliport;

(l) The UAV System will not be operated over properties smaller than two acres in size;

(m) Operations will be restricted to day only and weather conditions equivalent to VFR;

(n) The PIC will brief the VO and property owner about the operation and risk before the first flight 

at each new location; 

(o) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight. 

PRE-FLIGHT CHECKLIST

(1) Use voltmeter to determine that UA battery is fully charged in order to prevent unexpected 

premature descent;

(2) Check all wiring connections are tight;

(3) Check all propellers are undamaged and no cracks exist in any structural members of the UAV; 

(5) Turn on radio controller, check for adequate voltage, set it to connect to the UAV, move all

control switches to forward or down position and throttle control stick full back position; 

(6) Connect UA main battery, check for radio contact with UA’s radio receiver;

(7) At a location different from previous flight, re-set GPS and compass to current location;

(8) Turn on transmitter, gimbal and camera.