Superior Perspective, LLC 

1524 Devonwood Dr. 

Springfield, IL 62704 

1-800-814-6940 

Business@SuperiorPerspective.com 

August 10, 2015 

US Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Exemption Request for commercial operation of Unmanned Aircraft Systems under Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 

11, Superior Perspective hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to 

allow commercial operation of its small Unmanned Aircraft Systems (sUASs), so long as such operations are 

conducted within and under the conditions outlined in this petition for exemption, the enclosed Motion Picture and 

Television Operations Manual (MPTOM), the enclosed sUAS operations and/or instructions manuals, or as may be 

established by the FAA as required by Section 333. 

As described more fully below, the request exemption permit commercial operation by Superior Perspective, which 

will utilize the DJI Phantom 3 and DJI Inspire 1 small Unmanned Aircraft Systems for ftight training, aerial 

photography, videography, digital imagery, and data acquisition to be used specifically for closed-set motion 

picture and television filming, journalism and news gathering, special events, real estate, precision agriculture, 

environmental management, scientific analysis, and for inspection of land, structures, and construction projects. 

Commercial operation under this exemption shall be limited to operations in day VFR conditions at low altitude in 

airspace that is permitted in accordance with the approved Certificate of Authorization (COA) at the time of 

operation and shall be subject to strict operating requirements and conditions set forth below to ensure at least an 

equivalent level of safety to those of currently authorized operations utilizing manned aircraft. Approval of this 

exemption would ultimately provide safer operation, improved quality, and improved affordability to the existing 

industry currently utilizing manned aircraft thereby promoting industry growth and fulfilling the Secretary of 

Transportation'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:' 

For your convenience, Superior Perspective has organized this exemption request as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested 

VI. Public Interest 

VII. Federal Registry Summary 

VIII. Conclusion 
I. Petitioner's Description 

Superior Perspective LLC, headquartered in Springfield, Illinois, is a company that will provide sUAS flight for use 

in news, agriculture, education, real estate, special events, film and movie production, and for sUAS flight training 

and also plans on providing an expanding range of services in the sUAS market in the future. 

The CEO and Chief Pilot for Superior Perspective, Joseph L Sronce, is a dual rated commercial and instrument 

pilot for both "Airplane Single Engine Land" and "Rotorcraft-Helicopter" with over 12 years of military flight 

experience and 2000 hours of combine flight time. Mr. Sronce, a combat veteran, has organized, managed, and 

flown assets in a combat environment and is intimately familiar with maintaining safety and minimizing risk during 

the riskiest of operations. Mr. Sronce shall ensure the safety of all operations conducted by Superior Perspective 

through a set of Standard Operating Procedures which include but are not limited to minimum training and currency 

requirements for all Pilots In Command (PICs), Operating Procedures and Limitations for all UAS flights, risk 

identification and mitigation, and Emergency Procedures for each approved sUAS. These Standard Operating 

Procedures are outlined in Superior Perspective's Motion Picture and Television Operations Manual and are 

supplemented by the respective user manuals of each UAS. 

The contact information for Petitioner is as follows: 

Superior Perspective, LLC 

1524 Devonwood Dr 

Springfield, IL 62704 

1-800-814-6940 

Joseph L. Sronce, CEO/Chief Pilot 

Cell: 217-725-6229 

H. Relevant Statutory Authority 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the 

Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems 

into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider 

whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion 

of the formal UAS rule making, based on the following considerations: 

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

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

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

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". 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and 

minimum standards when the Administrator decides a requested exemption is in the public interest. A party 

requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and 

(2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). 

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. 
III. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the 

Reform Act. Each of the statutory criteria and other relevant factors are satisfied. 

The proposed operations would permit Superior Perspective the use of small UAS under controlled conditions in 

airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an Increased level of safety 

beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. 

Superior Perspective utilizes the DJI Phantom 3 and DJI Inspire I which are multi-rotor type, highly maneuverable, 

Unmanned Aircraft Systems that weight far less than 55 pounds and operate at speeds of no greater than 50 mph. 

The DJI multi-rotor system allows the UASs to hover and move freely and simultaneously in the vertical and 

horizontal plane. Superior Perspective shall operate its UASs within visual line of sight, during day VMC 

conditions, and shall only operate within a sterile area as approved by the ATO through the COA. Unless 

otherwise authorized by the FAA, Superior Perspective shall operate at or below 400 feet AGL and shall obtain 

required permissions and permits from territorial, state, county or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies prior to all operations. 

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, 

this exemption falls within the zone of safety and demonstrates an equivalent level of safety, in which Congress 

desired the FAA to permit commercial UAS operations by exemption while pending completion of formal rule 

making. Also, due to the size of the sUASs and the confined area in which the sUASs will operate, approval of the 

application presents no significant hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant 

of the requested exemptions is also in the public interest. 

IV. Description of Proposed Operations 

Superior Perspective proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent 

or even higher level of safety to operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe aerial photography and cinematography filming operations 

conducted with conventional manned aircraft. 

To assist the FAA in its safety assessment of Superior Perspective's proposed sUAS operations, below is a 

summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines: 

1. The sUASs shall weigh less than 551bs including payload. 

2. All sUASs used for operations shall 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 shall be as large as practicable. 

3. All sUAS's maintenance, and repairs shall be completed pursuant to the flight manual, operating handbook, 

and DJI technical support as applicable to each individual sUAS. 

4. At least 45 days prior to any scheduled filming a Certificate of Authorization (COA) request shall be 

submitted to the Air Traffic Organization via UAS COA Online System. 

5. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents 

required under 14 CFR §§ 91.9 and 91.203 shall be available to the Pilot In Command (PIC) at the Ground 
Control Station of the UAS any time the aircraft is operating. These documents shall be made available to 

the administrator or any law enforcement official upon request. 

6. Flights shall be operated within line of sight of a pilot and/or visual observer. 

7. UAS operations shall be conducted during during day visual meteorological conditions (V MC), as defined 

in 14 CFR § 1.1. 

8. Maximum total flight time for each operational flight shall be limited to the amount of time the sUAS can 

be flown and still maintain enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the manufacturer if 

greater. 

9. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an 

elevated platform for which filming is planned. 

10. The UA 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. 

11. All Flight operations shall be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles,and structures unless: 

- Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations shall cease immediately in a manner 

ensuring the safety of nonparticipating persons; and 

- The owner/controller of any vessels, vehicles or structures has granted permission for operating 

closer to those objects and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard; or 

- Flight operations closer than 500 feet from participating persons consenting to be involved are 

necessary for the filming production, as specified in the enclosed MPTOM. 

12. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual Observer. 

Additional crew may consist of a Camera Operator. 

13. Observer, PIC, and any other crew required shall at all times be able to communicate by voice and/or two 

way radio communication system. 

14. The Pilot in Command shall hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC shall also hold a current FAA airman medical certificate or a valid U.S. driver's license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC shall meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate. 

15. No pilot shall be permitted to operate unless the pilot demonstrates the ability to safely operate the UAS in 

a manner consistent with the enclosed MPTOM including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency shall be logged in a manner consistent with 14 CFR § 61.51(b). 

16. Flights for the purposes of training PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC's ability to safely operate the UAS shall only be conducted during dedicated training 

sessions. During such training, proficiency, and experience-building flights, all persons not essential for 

flight operations shall be considered nonparticipants, and the PIC shall operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

17. All operations shall be conducted in accordance with an ATO-issued COA. If there is intent to conduct 

operations that cannot be conducted under the terms of the attached COA, Superior Perspective shall apply 

for a new or amended COA. 

18. The UAS shall not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement 

with that airport's management is obtained or otherwise permitted by the issued COA. The letter of 

agreement with the airport management must be made available to the Administrator or any law 
enforcement official upon request. 

19. Superior Perspective shall submit a written "Plan of Activities" to the local Flight Standards District Office 

(FSDO) having jurisdiction over the area of proposed filming three days in advanced of operations during 

film or movie productions. 

20. If applicable, all required permissions and permits will be obtained from relevant property owners, 

controllers, or representatives and/or territorial, state, county, or city jurisdictions to include local law 

enforcements, fire, or other appropriate governmental agencies. 

21. A preflight briefing including all involved parties shall be conducted in regards to the planned sUAS 

operations prior to each day's production activities to include a site inspection, weather brief, identification 

of potential hazards and risks, and risk mitigation. Each pilot in command shall, before beginning a flight, 

become familiar with all available information concerning that flight. 

22. The PIC shall ensure that the sUAS remains clear and gives way to all manned aviation operations and 

activities at all times. 

23. The UAS shall not be operated from any moving device or vehicle. 

24. In the event of an accident involving an MDV sUAS, they will cease operations and report the accident to 

the NTSB and AFS-80. 

25. If the event that a sUAS loses communications signal, the sUAS shall have the capability to return to a predetermined and pre-set location within the Sterile Area and land. 

26. In the case of an in-flight emergency to include loss of communication between the pilot and the observer, 

the PIC shall (1) maintain control of the sUAS to the max extent possible, (2) Fly the UAS to a safe area 

free of persons or property, (3) Abort the operation, (4) land the sUAS as soon as practicable as determined 

by the PIC. Flight operations shall not be resumed until the cause of the emergency is identified and 

corrected. 

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA shall be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site. 

V. Regulations From Which Exemption is Requested 

A. 14 CFR §61.113(a)&(b): Private Pilot Privileges and Limitations; Pilot in Command 

B. 14 CFR Part 21 Subpart H, §91.203(a)(1): Airworthiness Certificates 

C. 14 CFR §45.23(b): Marking of the Aircraft 

D. 14 CFR §91.203(a)(2), §91.9(b)(2): U.S. Registration Certificate & Civil Aircraft Flight Manual in the 

Aircraft 

E. 14 CFR §91.119: Minimum Safe Altitudes 

F. 14 CFR §91.121: Altimeter Settings 

G. 14 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions 

H. 14 CFR §91.405(a), §91.407(a)(1), §91.409(a)(2); §91.417(a)&(b): Maintenance Inspections 

I. 14 CFR §91.109: Flight Instruction 

A. 14 CFR §61.113(a)&(b): Private Pilot Privileges and Limitations; Pilot in Command 

Superior Perspective respectfully requests and exemption from 14 CFR §61.113(a)&(b) which limits private pilots 

to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the DJI 

Phantom 3 and Inspire 1 are remotely controlled with no passengers or property on board, no flammable fuel, and 

weight less than 55 lbs. Therefore Superior Perspective proposes that the actual operation of a sUAS does require 

that the pilot at the controls hold a conventional pilot certificate. Nevertheless, Superior Perspective also proposes 

that a PIC is required at the Ground Control Station that holds at least an airline transport, commercial, private, 

recreational, or sport pilot certificate. This requirement is necessary because of the need for understanding of 

different airspaces and current FAA regulation applicable in sUAS operation. Not unlike conventional manned 
aircraft the pilot at the controls may not necessarily be the pilot in command. Also as in conventional manned 

aircraft, the PIC shall have direct two way communication with all crew, shall be responsible for the overall safety 

of flight operations including extensive knowledge of applicable regulations and airspace, and shall have the 

capability to assume control of the sUAS at any time in the case of necessity or emergency. 

Equivalent Level of Safety shall be maintained because Superior Perspective will utilize both a PIC and a Pilot 

crew system. This system will add a level of safety to the cunent safety requirements being authorized by the FAA 

because it will allow the pilot at the controls to concentrate on flying and filming while while the PIC is free to 

concentrate on the safety of the entire operation. It will also alleviate the undo burden of expensive and timely 

conventional flight training for sUAS pilots which does not directly translate into the necessary skill set for a pilot 

to safely fly/operate a sUAS. Minimum Requirements for qualification as both Pilot and PIC are established in the 

enclosed MPTOP. 

B. 14 CFR Part 21 Subpart H, §91.203(a)(1): Airworthiness Certificates 

Superior Perspective respectfully requests an exemption from 14 CFR Part 21 Subpart H, entitled Airworthiness 

Certificates, which establishes the procedural requirements for the issuance of airworthiness certificates as required 

by FAR §91.203(a)(1). Given the small size and limited operating area associated with the aircraft to be utilized by 

Superior Perspective, 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 Refonn 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. 

Equivalent Level of Safety shall be maintained because an analysis of these criteria demonstrates that an sUAS 

operated without an airworthiness certificate, in the restricted environment and under the proposed operational 

conditions conditions will be at least as safe, or safer, than a conventional manned aircraft operating with an 

airworthiness certificate without the restrictions and Proposed Operational conditions. Additionally, the PIC shall 

be responsible for determining whether the sUAS is in condition for safe flight and shall discontinue any flight 

when an unairworthy mechanical, electrical, or structural condition occurs. 

C. 14 CFR §45.23(b): Marking of the Aircraft 

Superior Perspective respectfully requests an exemption from 14 CFR §45.23(b) which requires that the applicable 

category of the aircraft be displayed "on that aircraft near each entrance to the cabin, cockpit, or pilot station" and 

that the lettering for the category and the N registration number be "not less than 2 inches nor more than 6 inches 

high: ' The sUAS has no entrance to the cabin, cockpit or pilot station on which any word can be placed and given 

the size of the sUAS, two inch lettering would be impossible. Superior Perspective proposes placing the lettering 

for the category of aircraft and N registration number in a location visible in flight and that the lettering shall be as 

large as practicable. 

D. 14 CFR §91.203(a)(2), §91.9(b)(2): U.S. Registration Certificate & Civil Aircraft Flight Manual in the 

Aircraft 

Superior Perspective respectfully requests an exemption from 14 CFR §91.203 and 14 CFR §91.9(b)(2) which 

require that no person may operate a civil aircraft unless an appropriate and current registration certificate and a 

flight manual are available inside the aircraft. The sUAS with its size and configuration, has no ability or place to 

carry a registration certificate or flight manual inside the aircraft nor is there a need to carry such items inside given 

that there will be no pilot or crew onboard. 

The equivalent level of safety will be maintained by keeping the appropriate and current registration certificate and 
flight manual at the Ground Control Station where all crew and involved personnel will have immediate access to 

them as required. 

E. 14 CFR §91.119: Minimum Safe Altitudes 

Superior Perspective respectfully requests an exemption from the minimum safe altitude requirements of 14 CFR 

91.119 that prescribes the minimum safe altitudes under which aircraft may operate: 

Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude 

of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

Over other than congested areas at an altitude of 500 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. 

Given the small size, limited speed, and lack of flammable fuel a sUAS, the danger in flying a sUAS is not to 

"persons or property on the surface" but rather to other aircraft flying above. Therefore Superior Perspective 

proposes that a minimum safe altitude it is not required and that, in lieu, a maximum safe altitude be established in 

order to ensure separation between the sUAS and those conventional aircraft that are required to comply with 

Section 91.119. 

Equivalent Level of Safety shall be maintained because the risk associated with low level sUAS operation is far less 

than those presently presented with conventional aircraft operating at or below 500 AGL in the aerial photography 

and cinematography industry. To mitigate the risk of low-level flight to persons and property and to ensure 

separation between the sUAS and conventional aircraft, Superior Perspective shall comply with limitations 

established in the approved COA for each operation. 

F. 14 CFR §91.121: Altimeter Settings 

Superior Perspective respectfully requests an exemption from 14 CFR 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS does not have a barometric 

altimeter, but rather a GPS altitude read out. 

An equivalent level of safety will be achieved through the use of the Preflight Check List located in the respective 

UAS's user manual. The pilot, pursuant to the Preflight Check List, shall confirm the altitude of the launch site 

shown on the GPS altitude indicator before flight and shall utilize the GPS altitude indicator to constantly monitor 

the UAS's height; thus ensuring operation at safe altitudes. 

G. 14 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Superior Perspective requests an exemption from 14 CFR §91.151(a) which mandates that during daytime 

operations no person may begin a flight in an airplane under VFR conditions unless there is enough fuel to fly to the 

first point of intended landing to fly after that for at least 30 minutes. The batteries powering Superior Perspective's 

UASs provide approximately 23 minutes of powered flight when fully charged. It is therefore impossible to 

comply with the 30 minutes reserve requirement in 14 CFR §91.151. Superior Perspective proposes that it shall 

maintain enough available power for the sUAS to conduct the intended operation and to operate after that for at 

least five minutes. 

Equivalent level of safety will be achieved because the UASs shall be operated within a limited, predetermined 

flight area and the takeoff and landing site shall therefore be the same. In addition the UAS's program gives ample 

warning when battery power drops below 33% and also automatically calculates a bingo battery life with included 
reserve based on altitude, distance, and required RTB flight profile. 

H. 14 CFR §91.405(a), §91.407(a)(1), §91.409(a)(2); §91.417(a)&(b): Maintenance Inspections 

Superior Perspective respectfully requests an exemption from the maintenance inspection requirements contained in 

14 CFR §91.405(a), §91.407(a)(1), §91.409(a)(2); §91.417(a)&(b). These regulations specify maintenance and 

inspection standards in reference to 14 CFR Part 43. 14 CFR §91.405(a) mandates that each owner or operator of an 

aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections ...have discrepancies repaired as prescribed in part 43 of this chapter." Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply if a civil aircraft 

airworthiness (14 C.F.R. §91.7(a)) exception is granted. 

Equivalent level of safety will be achieved due to the simplicity, light weight, and versatility of the sUASs which 

lack the moving parts and complicated systems that conventional manned aircraft possess. Small UASs therefore 

require far less maintenance and are far less likely to experience a system failure than a conventional aircraft. 

Furthermore an in-flight system failure of a sUAS poses significantly less risk to persons and property. In the case 

of an in-flight emergency/system failure of a sUAS, the PIC shall abort the operation and the sUAS shall be landed 

as soon as as soon as practicable. Inspections, maintenance, and repairs shall be completed pursuant to the flight 

manual, MPTOM, and DJI technical support as applicable to each individual sUAS. 

I. 14 CFR §91.109: Flight Instruction 

Superior Perception respectfully requests an exemption for 14 C.F.R. §91.109 which mandates 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. UASs are remotely piloted aircraft and by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a single control box that communicates with the 

aircraft via radio communications. Superior Perspective proposes that training be conducted with the instructor 

pilot within arms length of the trainee and that the sUAS be placed on its available training mode until the 

instructor pilot is confident that the trainee is ready to fly in normal flight mode. 

Equivalent Level of Safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, 

by the small size and slow speed of the aircraft, and by the designated and confined area of operation of the aircraft. 

Additionally the instructor pilot shall be at a distance to quickly assume the controls as necessary. 

VI. PUBLIC INTEREST 

Granting Superior Perspective an exemption will further the public interest by enhancing safety and improving 

industry through reduced cost and improved quality. Conventional commercial aerial photography and 

cinematography use turbo jet or piston powered aircraft which carry large amounts of combustible fuel, weight 

over 3000 lbs, and must be in-flight ferried to and from location of operation. Therefore when operated at low 

altitudes, they pose a significantly greater risk to crew, and persons and property below in addition to being costly 

to operate and very limited in their capabilities. The DJI Phantom 3 and Inspire 1 carry no combustible fuel, weigh 

less than 55 lbs, are much more maneuverable, and are inexpensive to operate. These characteristics allow Superior 

Perspective to offer the same service at significantly reduced risk, reduced cost, and improved quality over the use 

of conventional manned aircraft. In addition UASs are not required to be in-flight ferried to and from location 

thereby eliminating the associated additional cost to the client and eliminating additional risk to crew, persons, and 

property. For these stated reasons, it is clear that allowing the specified commercial operation of sUASs as 

described is ultimately in the best interest of the public. 

VII. Federal Registry Summary 
Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be 

determined that publication is needed: 

Superior Perspective, LLC seeks an exemption from the following regulations: 

14 CFR §61.113(a)&(b), 14 CFR Part 21 Subpart H, §91.203(a)(1), 14 CFR §45.23(b), 14 CFR §91.203(a)(2), 

§91.9(b)(2), 14 CFR §91.119, 14 CFR §91 .121, 14 CFR §91.151(a), 14 CFR §91.405(a), §91.407(a)(1), §91.409(a) 

(2); §91.417(a)&(b), 14 CFR §91.109 

Approval of this exemption would permit commercial operation by Superior Perspective, which will utilize the DJI 

Phantom 3 and DJI Inspire 1 small Unmanned Aircraft Systems for flight training, aerial photography, videography, 

digital imagery, and data acquisition to be used specifically for closed-set motion picture and television filming, 

journalism and news gathering, special events, real estate, precision agriculture, environmental management, 

scientific analysis, and for inspection of land, structures, and construction projects. 

VIII. Conclusion 

The approval of the requested exemption herein is in the public interest because allowing the specified commercial 

operation of sUASs as described will ultimately reduce risk, reduce cost, improve quality, and promote industry 

growth all while maintaining at least an equivalent level of safety to that of the operation of conventional manned 

aircraft. Additionally, the grant of the requested exemption will alleviate undue burden from the specified FAA 

regulations that were created outside the scope of sUAS operation and thereby unnecessary for the safety of such 

operation. 

Considering the equivalent level of safety surrounding the proposed operations, the significant public benefit, and 

the potential to promote industry growth, Superior Perspective submits that the exemption herein fulfills all statute 

criteria set forth in Section 333 of the FAA Modernization and Reform Act of 2012 and respectfully request 

approval without delay. 

in erely, 

Joseph L.Sronce 

CEO/Chief Pilot 

Superior Perspective, LLC