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APPLICATION/PETITION FOR EXEMPTION (Drone “UAV” Use)

Sean Murphy

Cannery Row Films, LLC

786 19TH Street SW

Vero Beach, Florida 32962

(772) 501-9861

Email: sean@canneryrowfilms.com

STATED SECTION(S) FOR RELIEF SOUGHT

COMES NOW, Cannery Row Films, LLC, herein after referred to as CRF, and 

does hereby submit and request exemptions to FAA Rules for drone (UAV) usage, and 

seeks stated Special Airworthiness Certificate - Experimental Category (SAC-EC). CRF 

is a domestic company that specializes in the production of videography and 

photography products for private and public clients. At all times, CRF’s carries 

insurance, is fully legal in the State of Florida and has NEVER operated a UAV at any 

time, prior to this application being filed.

RELIEF DEFINED FOR EXEMPTION

On September 25, 2014, the Federal Aviation Administration announced it will 

allow the use of unmanned aerial vehicles (UAVs) on some U.S. film sets. The FAA 

more specifically said, this is “the first step to allowing the film and television industry 

the use of unmanned aircraft systems (UAS) in the National Airspace System.” The 

Motion Picture Association of America (MPAA) has been successful and complied with 

the FAA in the past and CRF and its associates pray to do the same.

Cannery Row Films, LLC is a registered Limited Liability Company that is fully 

insured and residing and operating in the State of Florida. At all times, Cannery Row 

Films has refrained from the use of Drones, while others have defied such regulations. It 

is in CRF’s best interests, that we hold the FAA’s regulations, laws and policies to the 

standards as set forth and by spirit and application, apply for this exemption as required, 
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rather than pushing an issue outside the purviews of said FAA requirements as so many 

other have done and continue to do in the State of Florida.

BENEFIT TO THE PUBLIC

Since the applicant, CRF, more specifically Sean Murphy, has intimate, personal, 

functioning and real world training in aviation, we’d argue that his understanding and 

knowledge of the rules of flight, air traffic patterns, safety standards, aeronautics, time 

logged in aircraft, such as a Cessna 150, Cessna 152 and a Cessna 172, and hours in

training in ground school instruction, he in fact presents a more safe and compliant 

operator of a UAV, than that of the known average user and operator, which as of the 

writing of this, is almost nonexistent. This applicant knows the safety threat these 

vehicles can pose to air traffic, the general public and others, and as such, since he has 

a working, and real world knowledge, his operation of a UAV is far superior than that of 

an operator that merely buys a UAV and then operates it outside the confines and 

guidelines/regulations of the FAA.

SAFETY AND ADHERENCE AND BENEFIT THEREOF

CRF, shall at all times relevant, operate and adhere with their UAV, and 

understanding fully, “which must be flown within the line of sight of the operator, 

less than 400 feet above the ground, during daylight conditions, inside Class G 

(uncontrolled) airspace and more than five miles from any airport or other 

location with aviation activities.”

ARGUMENT IN SUPPORT OF APPLICATION

FAA Order 8130.34 is limited in scope. It does however address “civil operators”

in a way that the spirit of it speaks to the private sector being “included” in the 

exemption process for the operation of UAV’s. CRF, in the pursuit of their business 

specialty, understand the importance that UAV’s now play in film production. 

Increasingly, because of ever increasing limitations of budgets, the use of UAV’s has 
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become an attractive alternative to traditional aerial “film or photography shoots” for 

private sector clients, i.e., the Real Estate market and their professionals, survey 

companies, commercial sector clients, etc. A pure argument to UAV’s economic 

benefits is relative to and pertains to simple cost. (Example) A traditional hour of air time 

in a rotorcraft would be offered to a client at a minimum charge of $369.00 per flight 

hour, whereas a UAV could accomplish the same tasks and produce the same results 

for a fraction of the cost in that time, and be done in an expedient manner. Typical flight 

time to secure the desired results for a particular (typical) client is less than (15) minutes 

of actual flight time. And, the flight ceiling would be no more than a few hundred feet, if 

that (emphasis added), which actually poses a safer environment for the surrounding 

areas, than that of a traditional vehicle, i.e., aircraft or rotorcraft. This is especially true 

in a developed area, such as a neighborhood.

CRF’s, shall at all times, and as a minimum, observe all applicable regulations of 14 

CFR parts 61 and 91. This document is intended to identify alternate methods of 

compliance with the regulations when evaluating proposed UAS operations. Since 

CRF, in fact has, a person, in this case, the applicant himself, that was in fact, a student 

of flight, the applicant understands and has working knowledge of the rules of flight, air 

traffic patterns, safety standards, aeronautics, which CRF’s would argue is way beyond 

that of the typical and relevant average operator now existing and making use of an 

UAV.

SUMMARY

WHEREFORE, the applicant, CRF (Sean Murphy), respectfully requests a (24) 

month exemption to lawfully, within the stated regulations of the FAA and others, and as 

stated, operate a UAV for the sole purpose of producing client results relating to film, 

videography and still photograph shoots. FURTHER, it is stated and affirmed here, that 

CRF (Sean Murphy) has made application for the required Special Airworthiness 

Certificate - Experimental Category (SAC-EC).
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Respectfully submitted this 19th day of November, 2014.

____________________________

Sean Murphy

Creative Director/Managing Partner

Cannery Row Films, LLC

786 19TH Street SW

Vero Beach, Florida 32962

(772) 501-9861

Email: sean@canneryrowfilms.com