# FAA	333	Exemption Petition

Operator	name:

Ian	Choplick dba	ChopShop	Productions,	LLC. 168	Driggs	Ave.	#3R Brooklyn,	NY	11222 (818)	209

- 6198 ianchoplick@gmail.com

I am submit ting a petition for exemption by t he FAA for Ian Choplick dba as ChopShop Productions, LLC. to operate unmanned aircraft in the National Airspace System (NAS).

I am requesting to operate an unmanned aircraft system (UAS) to conduct aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities; operations for
closed

- set motion picture and television productions; aerial video and/or photography for public and/or private use including te levision, video production, public events, landscape cinematography and network news imaging; aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority; aerial video/photography or provi ding live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation; training to persons individually or belonging to both priv ate and/or public organizations to increase awareness and improve safety for current and future UAS operations within the National Airspace System ; wildlife and forestry monitoring; educational and research operations.

Ian Choplick is seeking relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36

Ian Choplick is seeking relief from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

I	am	request ing	these	exemptions	so	that	I	may	safely	operate	the	DJI	Phantom	3 Professional	and	the	DJI	Phantom	4 along	the	guidelines	of	the	accompanying operator's	manuals	as	well	as	FAA	guidelines	for	U AS flight	and	safety	guidelines	set	by the	Academy	of	Model	A eronautics	(AMA). Proposed	UAS	and	Operations

.

Proposed	UAS	and	OperationsThe DJI	Phantom	3	Professional	and	the	DJI	Phantom	4 will	always	be	flown	under	400

feet	limited	via software	by	its	GPS	and barometric	sensors,	is	electrically	powered	by	a

lithi um	ion	battery,	carriesno	combustible	fuel	or	crew,	and	will	be	transported	in proper	storage	to	and	from	all	flight	areas	(in accordance	with	FAA	guidelines).	The aforementioned	proposed	exemptions	would	allow	me	to operate	the DJI	Phantom	3

Professional and	the	DJI	Phantom	4 for	commercial	purposes	of	aerial	videography	and photography	as	a service	to	public	and	business	interests,	including:	real

- estate photography	and	videography,	wedding and	private	individual	photography	and videography,	public	and	co mmercial	photography	and videography,	and	agricultural photography	and	videography.

As	evidenced	by	recent	Exemption	Nos.	12045	and	12058,	the	FAA	recently	approved

similar	use	of t he DJI	Phantom	3	Professional	and	the	DJI	Phantom	4 .	These	particular

UAS ’ s have	been	proven	reliable	and	safe	flying	machines managed	by	gyroscopically

stabilized	flight,	ground	detection,	GPS

- aided	navigation,	a	built

- in compass,	blinking LED	lights,	a	manual	and	automatic	failsafe	"Return	To	Home"	mode	for returning	to	the

po int	of	takeoff,	and	propeller	guards	in	order	to	protect	both	the	UAS	and	the environment.	This	particular	model	combines	state

- of

- the

- art,	proven	technology	with high	quality manufacturing	and	user

- friendly	control	to	ensure	safe	operation	and	easy

mainte nance	and	care.



### Specific	section(s)	of	14	CFR	which	I	seek	relief	and	the	reason(s)	I	seek	relief:

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

Given	the	size	and	limited	operating	area	associated	with	the	UAS	to	be	utilized,	an exemption	from Part	21 meets	the	requirements	of	an	equivalent	level	of	safety	under

Part	11	and	Section	333	of	the Reform	Act.	As	evidenced	in	Exemption	No.	12045,	"in	all cases,	an	analysis	of	these	criteria demonstrates	that	the	UAS	operated	without	an

airworthiness	certifica te,	in	the	restricted environment	and	under	the	conditions proposed	will	be	at	least	as	safe,	or	safer,	than	conventional aircraft	operating	with	an airworthiness	certificate	without	restrictions	and	conditions	proposed."

14	C.F.R.	61.113(a) & (b):	Privat e	pilot	privileges	and	limitations:	Pilot	in	command

Under 

### § 61.113	(a)	and	(b),	certified	private	pilots	are	limited	to	noncommercial operations. However,	I	am	able	to	achieve	an	equivalent	level	of	safety	through	current FAA	regulations	of	UAS operation and	AMA	safety	guidelines	(outlined	in	the	summary of	this	document)	without	such	a certification	because	of	the	above	mentioned	safety

features	of	the DJI	Phantom	3	Professional	and	the	DJI	Phantom	4 .	According	to Exemption	No.	12045	in	which	the Phantom 3	Professional	and	Phantom	4	were authorized	for	similar	operation,	"The	FAA has	previously	declared	that	additional manned	airship	experience	of	a	commercially	certified	pilot would	not	correlate	to	the airmanship	skills	necessary	for	similarly	proposed operations	in	previously issued	exemptions	to	this	regulation	through	Exemption	Nos.	11062	and	11138." Therefore,	bearing any	pilot	certification	or	license	will	not	ensure	remote	piloting	skillsof	a	UAS;	the	risks	of	operating this	UAS	are	far	less	than the	risk	levels	inherent	in

commercial	activities	with	traditional	aircraft given	the UAS’s safety	features	and	the limited	range	and	speed	of	the	UAS.	The	FAA	has approved	a	similar	exemption	to	the above	rule	as	evidenced	in	Exemption	No.	12058.

14	C.F. R	91.7:	Civil	aircraft	airworthiness

Currently	there	is	no	ce rtificate	applicable	to	the	DJI	Phantom	3	Professional	and	the	DJI

Phantom	4 ,	and	therefore	it	will	be	up	to	myself, Ian	Choplick ,	to	determine	the

airworthiness	of	the UAS’s in	accordance	with its	official operating	manual.	Written	and signed	pre	and	post

- flight	inspections	of	the	propellers,	motors,	frame, landing	stands, camera	and	gimbal	unit,	connected	tablet	devices,	a	compass	calibration	and	properly ensured	GPS	locks	as	indicated	by	the P hantom	3	Professional	and	Phantom	4 display	of "Safe	to	Fly"	message	will	be performed	before	and	after	each	flight,	accurate	records	of which	will	be	kept	with	the	UAS's	storage and	transportation	system	at	all	times.	These

records	will	be	dated	and	will include	the	total	flight time	of	each	flight.

14	C.F.R.	91.9	(b)(2):	Civil	aircraft	flight	manual,	marking,	and	placard	requirements

As	evidenced	in	Exemption	12045,	since	there	are	"no	pilots	or	passengers	on	board this	aircraft,	and given	its	size,	thi s	regulation	is	inapplicable.	An	equivalent	level	of safety	will	be	achieved	by maintaining	a	safety/flight	manual	with	the	operator."	In addition	to	the	official	safety/flight	manual provided	by	DJI upon	purchase	of	the

Phantom	3	Professional	and	Phantom 4 ,	following	the	AMA	guidelines	for	safe flight operations	and	the	FAA	regulations	for	UAS	operations	will	ensure	a	high	level	of	safety.

14	C.F.R.	91.119(c):	Minimum	safe	altitudes

I, Ian	Choplick, will	ensure	that	the DJI	Phantom	3	Professional	and	the DJI	Phantom	4

will not	operate	any	higher	than	400	feet	at	ground	level by	setting	the	maximum

altitude	at	400	feet	in UAS’s pilot	application	and	ensuring	this	is set	before	each	flight as	part	of	the	pre

- flight	inspection.	I	will	not	fly	over	congested areas	or directly	above unprotected	people	or	moving	vehicles.	I	will	plan	operations	before	hand	for	proper flight	safety	and	proper	height	analysis	as	to	avoid	collisions.	The	GPS	and	barometric

sensors equipped	on	the UAS’s will	ensure	accurate	altitude readings,	the	output	of

which	will	be	fed to	my	tablet	device	in	real	time	as	I	operate	the	UAS.

14	C.F.R.	91.121:	Altimeter	settings

The Phantom	3	Professional	and	Phantom	4	utilize the	latest	GPS/GLONASS technologies	as	well	as	a	barometric	sensor wit h	live	data	output	to	the	tablet	device attached	to	the	transmitter.	An	equivalent	level	of	safety	and accurate	altimeter telemetry	will	be	achieved	by	using	this.

14	C.F.R.	91.151(a)(1):	Fuel	Requirements	for	flight	in	VFR	conditions

The Phantom	3	Profe ssional	and	Phantom	4	are electrica lly powered	by	lithium	ion

batteries which	are	made	by	DJI specifically	for	this	particular	UAS.	They	are	rated	asproviding	no	longer	than	30	minutes	of	flight time.	Therefore,	due	to	the	limitations	of the	batteries,	it is	currently	impossible	to	comply	with	part

91.151.

14	C.F.R.	91.203(a)	and 

### (b): Civil	aircraft:	Certifications	required

Currently,	there	are	no	procedures	for	providing	airworthiness	certificates	for	the

mentioned DJI	Phantom	3	Professional	and	the	DJI Phantom	4 .	I, Ian	Choplick ,	however will	always	fly	safely	while	having	the	manuals	of	the UAS’s and abiding	by	FAA regulations	for	UAS	operation	and	AMA	safety	guidelines.

14	C.F.R.	91.405(a):	Maintenance	Required,	14	C.F.R.	91.407(a)(l):	Operation	afte r maintenance, preventive	maintenance,	rebuilding,	or	alteration,	14	C.F.R.	91.409(a)(l) and	(2):	Inspections 

### & 14 C.F.R.	91.417	(a)	and	(b):	Maintenance	records

.

Maintenance	inspections	may	be	required	and	should	be	granted	since	they	apply	to

aircraft	w ith	an airworthiness	certificate.	However	I, Ian	Choplick ,	will	perform	both preflight	and	post

- flight inspections	of	the	UAS	before	and	after	each	flight	as	outlined in	the	operating	documents.	I, Ian	Choplick ,	will	also	follow	manufacturer

recommendation s	from	said	operating	documents	and	keep	a written	record	of	any

maintenance	done	to	the	UAS.

Public	Interest	and	Public	Safety:

Aerial	photography	and	videography	provided	to	the	public	allows	for	a	more	cost

effective,	safe, and	environmentally friendl y	method	to	capturing	imagery	than	its

alternative:	manned	aircraft	and helicopters.	The	latter	are	expensive	to	operate	and maintain,	create	a	high	level	of	noise,	and	are much	more	hazardous	due	to	size	and

combustible	fuel

- especially	if	flown	at	low	a ltitudes	required for	some	operations.	I, Ian	Choplick ,	in	addition	to	using	my	UAS	for	commercial	endeavors, I will also	gladly offer	my	services	free	of	charge	upon	request	and	with	proper	coordination	to	any

official search	and	rescue	or	emergency	servi ces	organization	to	benefit	the	public. Because	of	this,	an increase	of	commercial	activity	and	a	gaining	of	more	detailed understanding	of	private	and/or	farm land	would	help	local	and	area	communities	by: reducing	pollution,	risk,	and	operating	costs	by alternative	aerial	video	and photography	services	such	as	manned	airplanes	and	helicopters,	reducing carbon emissions	and	traffic	congestion	by	vehicles	looking	to	view	properties	such	as	real

estate	or farm	land,	and	increase	visibility	to	local	attractio ns	thereby	bolstering	local

commerce	and	tourism.

Given	that	there	is	no	fuel	an d	no	crew	on	the	DJI	Phantom	3	Professional	and	the	DJI

Phantom	4 ,	and	having	a maximum	speed	(less	than	44 mph),	safe	operation	of	this	craft does	not	pose	any	immediate dange r	to	the	environment,	wildlife,	infrastructure	or people.	Given	its	GPS	and	ground

- sensing capabilities,	a	failsafe	"Return	To	Home" mode	will	safely	return	the	craft	to	the	operator	at	the	push of	a	single	button	or automatically	when	the	craft	is	either low	on	power	or	operating	outside	of	its transmitter's	range.	This	ensures	that	the	craft	will	not	remain	airborne	in	unsafeconditions	and	pose any	public	danger.



### All UAS models will be in compliance with registration and safety requirements . S tarting

fro m flight pre

- check and regular maintenance to the active rules and regulations of flying UAS’s defined by the FAA to upgrades and compliances, Ian Choplick will keep documents recording all functions of operation. All operations will utilize a visual
obser ver (VO). The UAS will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The PIC will always maintain VLOS capability. The VO and PIC will be able to communicate verbally at all times

. Maintaining these and other requiremen ts issued by the FAA will provide a high level of safety during operations.

SUMMARY

I,	Ian	Choplick,	am	seeking	exemption	from	the	following	rules:	14	C.F	.R.	Part	21,	14 C.F.R.	45.23(b),	14	C.F.R.	61.113(a),	14	C.F.R.	91.7(a),	14	C.F.R.	91.9(b)(2),	14	C. F.R. 91.119(c),	14	C.F.R.	91.121,	14	C.F.R.	91.151(a)(l),	14 C.P.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)(l)	and	(2),	14	C.F.R.	91.417(a)	and (b).

With	the	exemptions	of	the	mentioned	rules	I,	Ian	Choplick,	wil l	be	seeking	to	make	my UAS	photography/videography services	available	to	public	and	commercial	interests. The	FAA	has	authorized	similar	operations under	Exemption	Nos.	12045	and	12053. Alternatively,	public	and	commercial	interests	had previously	sought the	use	of	manned aircraft	to	achieve	what	I	can	offer	in	a	safer,	more	cost efficient and	environmentally friendly	manner	by	not	using	combustible	fuel,	flying	at	safe	heights and	strictly following	the	usage	recommendations	from	Chroma	and	safety	procedur es	by	the Academy	of	Model	Aeronautics.

These	include	but	are	not	limited	to: •	Flying	the Phantom	3	Professional	and	Ph anton	4 safely	in	accordance	with	its operator's	manual

. •	Always	flying	below	400	feet,	using	the Phantom	3	Professional	and	Ph anton	4

altitude	read	out	to	ensure	this. •	Completing	thorough	inspection	of	UAS	before	and	after	flight s	and	keeping	inspection

record with	the	cr aft	at	all	times •	Keeping	the	UAS	in	visual	sight	at	all	times	when	in	operation •	Using an visual observer	to	assist •	Remaining	safely	clear	of	and	not	interfering	with	manned	aircraft	operations •	Not	flying	directly	over	unprotected	persons	or	movi ng	vehicles •	Not	flying	within	5	miles	of	an	airport	or	control	tower •	Not	flying	in	adverse	weather	conditions	such	as	high	winds,	rain,	or	impaired visibility •	Not	flying	under	the	influence	of	alcohol	or	drugs •	Ensuring	the	operating	environment	is safe •	Not	flying	over	sensitive	infrastructure	or	property	such	as	power	stations,	water

treatment facilities,	correctional	facilities,	etc. •	Checking	and	following	all	local	laws	and	ordinances	before	flying	over	private

property•	Not	conducting	survei llance	or	photographing	persons	in	areas	where	there	is	an expectation	of privacy	without	the	individual's	permission



### Granting my request for exemption would strengthen the safety ethos of flying UAS’s as I will abide, display, adhere and administer high q uality operation, registration and

maintenance to all UAS’ s involved in my operations, a s well as mentor to future upcoming operators and VO’s and PIC’s. I will also provide visual documentatio n and

data collection to be resourced , learned and entertaining to public.

If	there	are	any	questions	or	concerns	for	my	petition,	please	contact	me	at	(818)

209

- 6198	or ianchoplick@gmail.com

.

Sincerely,

Ian	Choplick