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 submitting a petition for exemption by the 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 television, 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 providing 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 private 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	requesting	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	UAS flight	and	safety	guidelines	set	by	

the	Academy	of	Model	Aeronautics	(AMA). Proposed	UAS	and	Operations.

Proposed	UAS	and	Operations
The	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	

lithium	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	commercial	photography	and videography,	and	agricultural	

photography	and	videography.

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

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

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

point	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	

maintenance	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	certificate,	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):	Private	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	skills	
of	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	certificate	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	Phantom	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,	this	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 with	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	Professional	and	Phantom	4	are electrically	powered	by	lithium	ion	

batteries which	are	made	by	DJI	specifically	for	this	particular	UAS.	They	are	rated	as	
providing	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	after	

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	with	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	

recommendations	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	costeffective,	safe, and	environmentally	friendly	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	altitudes	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	services	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	realestate	or farm	land,	and	increase	visibility	to	local	attractions	thereby	bolstering	local	

commerce	and	tourism.

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

Phantom	4,	and	having	a maximum	speed	(less	than	44mph),	safe	operation	of	this	craft	

does	not	pose	any	immediate danger	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	unsafe	
conditions	and	pose any	public	danger.

All UAS models will be in compliance with registration and safety requirements. Starting 

from 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 

observer (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 

requirements 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,	will	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	procedures	by	the

Academy	of	Model	Aeronautics.

These	include	but	are	not	limited	to:

•	Flying	the	Phantom	3	Professional	and	Phanton	4 safely	in	accordance	with	its	

operator's	manual.

•	Always	flying	below	400	feet,	using	the	Phantom	3	Professional	and	Phanton	4

altitude	read	out	to	ensure	this.

•	Completing	thorough	inspection	of	UAS	before	and	after	flights	and	keeping	inspection	

record	with	the	craft	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	moving	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	surveillance	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 quality operation, registration and 

maintenance to all UAS’s involved in my operations, as well as mentor to future 

upcoming operators and VO’s and PIC’s. I will also provide visual documentation 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