May 22, 2015 

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave S.E. Washington, D.C. 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform 

Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R 21(h); 14 

C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 

C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 

C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b) and (c); 14 C.F.R. 121; 14 

C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 

405 (a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417. 

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, SkyShot Productions, an operator of Small Unmanned 

Aircraft Systems (“sUAS”) equipped to film and photograph real estate in rural areas in 

the state of California, applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, 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. 

Approval of exemptions for SkyShot Productions will allow commercial operations of 

sUASs in suburban areas of Los Angeles, CA, for the purpose of real estate photography 

and videography. The requested exemption should be granted because the proposed 

operations of the DJI Phantom 2, a small UASs that weighs 2.9 lbs., inclusive of battery 

and payload, conducted in the strict conditions outlined below, will provide an equivalent 

level of safety, as Congress intended, while still allowing commercial operations. The 

lightweight aircraft covered by the exemption are far safer than conventional operations 

conducted with manned helicopters and fixed-wing aircraft weighing thousands of 

pounds, containing highly flammable fuel, and operating in close proximity to the ground

and people, as a similar UAS has been previously approved in Exemption No. 11138, 

Douglas Trudeau, Realtor®. The seven factors Congress directed the FAA to consider 

when approving Section 333 exemption petitions - size, weight, speed, operational 

capability, proximity to airports, proximity to populated areas, and operation within 

visual line of sight – each support the request. In particular, the aircraft are small, and 

will operate at slow speeds, close to the ground, far from airports and in a low risk, low 

population environment. In addition, the substantial experience of the PIC weighs heavily 

in favor of granting the exemption. 

Pursuant to 14 C.F.R. 11.35, SkyShot Productions requests confidential treatment for 

certain information provided with this request for exemption. Specifically, SkyShot 

Productions requests that information contained in its user manual, SkyShot Production’s 

operating procedures, not be made public due to the proprietary information that the 

application has not and will not share with others. Additionally, SkyShot Productions 

requests that personal information related to the PIC not be made public in order to 

protect his identity. These documents are not available to the public and are protected 

from release under the Freedom of lnformation Act 5 U.S.C. 552 et seq. 
For your ease in reviewing this petition refer to the table of contents which begin on page 

three. If we can provide any additional information to assist your understanding or review 

of this document, please do not hesitate to contact us at 818-577-7036 or email us at 

Paul.Gross@me.com

Thank You,

Paul Gross

Owner/Operator

SkyShot Productions

23371 Mullholland Drive 

#270

Woodland Hills CA 91364 

+1.8185777036

paul.gross@me.com
Exhibit List (Submitted Separately)

Exhibit 1: DJI Phantom 2 Manual 

Exhibit 2: Phantom 2 – Features 

Exhibit 3: Phantom 2 – Specs 

Exhibit 4: Naza-M V2 Quick Start Guide 

Exhibit 5: 5.8G Video Link User Manual 

Exhibit 6: iOSD mini User Manual

Exhibit 7: DJI No Fly Zones 

Exhibit!8:!Phantom!2–Release!Notes

Exhibit!9:!Valid!California!Drivers!License

I. Publishable Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 

C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 

91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b) and (c); 14 

C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 

405 (a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417. 

Approval of exemptions for SkyShot Productions will allow commercial operations of 

sUASs in suburban areas of Los Angeles, CA, for the purpose of real estate photography 

and videography. The requested exemption should be granted because proposed 

operation of the DJI Phantom 2, a small UASs weighing 2.9 lbs., inclusive of battery and 

payload, conducted in the strict conditions outlined below, will provide an equivalent 

level of safety, as Congress intended, while still allowing commercial operations. The 

lightweight aircraft covered by the exemption are far safer than conventional operations 

conducted with helicopters and fixed-wing aircraft operating in close proximity to the 

ground and people. The seven factors Congress directed the FAA to consider when 

approving Section 333 exemption petitions - size, weight, speed, operational capability, 

proximity to airports, proximity to populated areas, and operation within visual line of 

sight – each support the request. In particular, the aircraft are small, and will operate at 

slow speeds, close to the ground, far from airports and in a low risk, low population 

environment. In addition, the substantial experience of the PIC weighs heavily in favor of 

granting the exemption. 

II. Petitioner’s*Contact*Information*

SkyShot Productions

23371 Mullholland Drive #270

Woodland Hills, Ca 91364

Tel: 818-577-7036

Email: paul.gross@me.com 

III. SkyShot Productions*Operations*
A. The sUAS 

The requested exemption will permit the operation of the DJI Phantom 2. The Phantom 2 

is a small, unmanned multirotor aircraft, weighing 2.9 lbs. inclusive of batteries, the 

propeller guard, and technical payload. This rotorcraft can operate at a speed up to 29 

knots, but SkyShot Productions will limit the speed to no more than 20 knots. The FAA 

has previously granted Exemption No. 11138, allowing commercial flight of a member of 

the DJI Phantom 2 family, the Phantom 2 Vision+. Exemption No. 11138 is attached to 

this petition as Exhibit 10. 

The sUAS will have the following specifications: 

Airframe: DJI Phantom 2

Flight Control System: Naza – M V2, which includes the main controller (MC), internal 

measurement unit (IMU) with built-in internal sensor, barometric altimeter, which 

measures attitude and altitude, compass, GPS, and radio receiver (Rx).

Transmitter (Tx): Futaba T14SG

Receiver (Rx): Internal to DJI Phantom 2

Data Link: 2.4G Data Link

Video Link: DJI AVL 58

Gimbal: H3-3D Zenmuse Gimbal for GoPro Hero

Camera: Go Pro Hero 4 Black

Batteries: 3S LiPo, 5200-mAh, 11.1V

iOSD: DJI iOSD mini, which allows live telemetry to be displayed on the video monitor, 

including the battery level, and altitude. 

Please refer to Exhibits 1-8 for further information about the sUAS and transmitter. 

B. Flight Conditions 

The sUAS will be flown in airspace under 200 feet above ground level (“AGL”) and 

under controlled conditions in rural areas. The majority of flights will take place under 

100 feet AGL. SkyShot Production’s operations will occur in suburban areas of Los 

Angeles focusing in the Thousand Oaks, Westlake Village, Agoura Hills and Calabasas 

areas of Los Angeles county and Ventura County. Skyshot Productions will avoid 

congested and densely populated areas and will work with local Flight Standard District 

Offices to determine safe areas to fly in. Skyshot Productions will only operate its sUAS 

in VMC, visual meteorological conditions: no less than 500 feet below and no less than 

2,000 feet horizontally from a cloud or when visibility at least 3 statute miles from the 

PIC. The flight crew will always make a safety assessment of the risk of every operation, 

and will only operate when it is determined that no undue hazards are present. 

C. Flight Operations 

Skyshot Production’s flight operations require that the sUAS will always be in the line of 

sight of both a PIC and a monitor specialist, who will also act as the visual observer 

(VO). Flights will be at altitudes of no more than 200 feet AGL, and at speeds less than 

20 knots. Despite the 200 ft. AGL limit, most flights will take place at an altitude of no 

more than 100 ft. AGL. The PIC has over twenty years of experience with RC aircraft, 

and has over 200 hours flying sUAS as a hobbyist. 
The week of an operation, the flight crew will file a flight plan with the local FSDO and 

contact ATC. The day before an operation, the flight crew will visit and inspect for safety 

the area in which operations will take place. The flight crew will also contact any 

neighbors to notify them of the filming. The sUAS will only fly over land which it has 

permission from the landowner or landowner’s agent to fly above. The notification will 

consist of, at minimum, the time, place, and type of UAS operation being conducted. The 

flight crew will also conduct a safety briefing with the property owners. 

Operations will not take place in congested and the PIC will work with the local FSDO 

when planning operations. The flight crew will obtain all aeronautical and weather data 

information, as laid out in Section 6 of the Operations Manual. Exhibit 1. 

On the day of filming, the flight crew will wear florescent shirts or vests to increase 

visibility. Prior to departing for an operation, the flight crew will briefly turn on the 

sUAS to ensure that everything is connected and that the sUAS is in operational 

condition. 

Upon arrival at a location for filming or photography, the flight crew will conduct an 

aerial and ground preflight inspection. 

The flight crew will then set out traffic cones to designate the aircraft’s “home area,” 

which will be a circle of approximately 20 feet in diameter to mark the sUAS take-off 

and landing zone. 

Note: If the radio control link is broken during flight, the autopilot system will recognize 

this broken control link and cause the sUAS to automatically return to the home area as 

recorded by the GPS instrumentation. 

The flight crew will conduct a physical inspection of the aircraft. The flight crew will 

then power on the sUAS and set up a laptop connected to the sUAS with the DJI AVL 58 

video link. This laptop will display the telemetry information during the flight, and be 

monitored by the VO. The VO will be able to see the images taken by the GoPro camera 

in real time. 

At any time during the flight, should the aircraft lose connection with the remote control, 

the flight control system failsafe will be activated automatically, and the aircraft will to 

return to the previously-set home area and land, in order to reduce injuries or damage. If 

any of the following 7 situations occur, the aircraft will not receive a signal, and enter 

into this failsafe mode: 

• The remote control is powered off; 

• The aircraft has flown out of the effective communication range of the remote 

control, which is no greater than 1,000 meters (3,280 feet); 

• There is an obstacle obstructing the signal between the remote control and the 

aircraft, essentially reducing the distance the signal can travel; or 

• There is interference causing a signal problem with the remote control. 

For further information regarding the DJI Phantom 2’s failsafe functions, please 

refer to Exhibit 1, the DJI User Manual, Section 6.4, beginning on page 25 of that 

document, and Exhibit 4, the Naza-M V2 flight control guide, section on 

Advanced Functions, beginning on page 16 of that document. 

The DJI Phantom 2 also has “no fly zones” programmed into it, which will 

prevent flights in restricted zones. Although SkyShot Productions will take every 

precaution to avoid flying in airspace other than class G airspace, the 

preprogrammed “no fly zones” will add an additional level of safety to operations. 
For further information regarding the DJI’s “no fly zones,” please refer to Exhibit 

1, Section 6.7 of the DJI User Manual, beginning on page 28 of that document, 

and Exhibit 7. Other than this automated feature of the DJI Phantom 2, the PIC 

will always fly the sUAS manually. The PIC and VO have tested the sUAS in a 

variety of weather conditions, including on overcast days and in winds up to 15 

knots. The PIC and VO will not fly the sUAS in heavy rainstorms, due to 

decreased visibility and the potential for water damage to the sUAS. The PIC and 

VO have also practiced emergency bailout procedures by having the sUAS return 

to home. In the event of an emergency, the PIC will release the joysticks. This 

will make the sUAS automatically hover in place and maintain its position and 

altitude, and the PIC and VO can determine if and when it is safe for the sUAS to 

return to the home location. 

During flights, the PIC and the VO will be standing next to each other, in oral 

communication at all times at the ground station. The VO will observe the 

telemetry data on the laptop and will monitor the images from the camera from 

the laptop. The VO will direct the PIC if she wishes to capture a different angle 

on the camera. The Go Pro Hero 4 Black camera will be filming or taking still 

images at intervals during the entirety of the flight and is not controlled 

independently from the ground station, other than by the movement of the sUAS. 

Flights will be limited to 18 minutes, which is 75% of the total battery life of the 

DJI Phantom 2. Once the sUAS has landed, the PIC will conduct a post-flight 

checklist as set out in Appendix D of the Operations Manual. 

IV. Privacy 

There is little concern that the proposed flights will cause invasions of privacy 

because all flights will occur over rural property with the property owner’s prior 

knowledge and consent. The only people and/or property to be filmed will have 

requested and hired SkyShot Productions for the express purpose of filming and 

photographing the people and/or property with the sUAS. 

No attempt will be made to identify any individuals filmed or photographed 

during the flights who have not consented to be filmed or photographed, except in 

cases where they are trespassing upon or damaging customer property, or 

interfering with the applicant’s or its customers’ operations 

V. Aircraft and Equivalent Level of Safety 

SkyShot Productions 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 higher level of safety to operations under 

the current regulatory structure. 

These limitations and conditions to which SkyShot Productions agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh significantly less than fifty (50) lbs. The DJI Phantom 2 

weighs 2.9 lbs., inclusive of battery and payload. 

2. Flights will be operated within line of sight of a pilot and VO. 
3. Maximum total flight time for each operational flight will be 75% of battery life. 

Flights will be terminated once the battery reaches a 25% level. This data will be 

available through telemetry data submitted to the transmitter and monitor. 

4. The sUAS will remain clear and yield the right of way to all other manned 

operations and activities at all times. 

5. Flights will be operated at an altitude of no more than 200 feet AGL. Despite this 

limitation, the majority of flights are anticipated to operate at no more than 100 

feet AGL. 

6. Minimum crew for each operation will consist of the sUAS PIC and VO. 

7. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s activities. It will be mandatory that all personnel who will be 

performing duties in connection with the operations be present for this briefing. 

8. The operator will obtain a FAA UAS Civil COA prior to conducting any 

operations under this grant of exemption. 

9. The operator will request a Notice to Airman (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation. 

10. At least three days before scheduled filming, the operator of the sUAS will submit 

a written Plan of Activities to the local FSDO with jurisdiction over the area of 

proposed filming. 

11. The PIC and VO have practiced the DJI Phantom 2 for approximately 120 

minutes a day for 2 months, translating to at least 200 hours of flight on this 

model. Practice flights have been in a variety of weather conditions, including in 

winds up to 15 knots and on overcast days. Practice flights have also included 

using the DJI Phantom 2’s emergency return-to- home features. 

13. The PIC and VO will at all times be able to communicate by voice and be 

stationed next to each other at the ground station. 

14. Written and/or oral permission from the landowner or authorized agent, of the 

land over which the sUAS will be flying. 

15. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

16. The sUAS will have the capability to abort a flight in case of unexpected 

obstacles or emergencies. The PIC and VO have practiced the emergency failsafe 

procedures, as described above on pages 6-7. 

17. If the multirotor and its controller disconnects during flight, the system’s failsafe 

protection will come to the rescue and the multirotor will return to home and land 

automatically, rather than flying off uncontrollably or landing at an unknown 

location. For more information on the failsafe procedures, please refer to Exhibits 

1-5. This condition is similar to one granted in Exemption No. 11138, attached to 

this petition as Exhibit 8. 

VI. Public Interest and Safety 

Use of the sUAS will increase ground safety by eliminating the need to have a manned, 

aircraft take the videos or photographs. As the FAA recognized in the Douglas Trudeau, 

Realtor® Exemption, No. 11138: 
“Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 

more, are operated by an onboard pilot and may carry other onboard crewmembers, as 

well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The 

pilot and crew will be remotely located from the aircraft. The limited weight reduces the 

potential for harm to persons or damage to property in the event of an incident or 

accident. The risk of an onboard pilot and crew during an incident or accident is 

eliminated with the use of a (iv) (v) within Class G airspace; and

outside of 5 statute miles from any airport, heliport, seaplane base, spaceport, or other 

location with aviation activities.” 

[sUAS] for the proposed operation.” Exhibit 10 at 11-12. 

As in the cited exemption, SkyShot Productions will use a member of the DJI Phantom 

family, the DJI Phantom 2. This sUAS also weighs 2.9 lbs., inclusive of battery and 

payload. 

During SkyShot Production’s operations, the PIC and VO will similarly be safely on the 

ground, directing the DJI Phantom 2 at altitudes no higher than 400 feet AGL. SkyShot 

Productions will not fly over congested or densely populated locations, and will work 

with local FSDO when planning operations. SkyShot Production’s flight crew will make 

a safety assessment prior to each operation, and will only operate when there are no 

undue risks. 

The small weight, 2.9 lbs., is less than the size envisioned in Section 334(c)(2)(C) of the 

FAA Modernization and Reform Act of 2012, which allows government agencies “to 

operate unmanned aircraft weighing 4.4 pounds or less, if operated –

1. (i) within the line of sight of the operator; 

2. (ii) less than 200 feet above the ground; 

3. (iii) during daylight conditions; 

Congress’s determination that government agencies should be allowed to operate such 

aircraft in these situations, with no further restrictions on location, population density, or 

pilot experience and training, indicates that Congress did not believe that aircraft of this 

size and weight warranted additional attention. 

VII. Regulations from Which Exemption is Requested A. 14 C.F.R. 21(h): 

Airworthiness Certificates 

SkyShot Productions requests an exemption from 14 C.F.R. 21(h). This exemption meets 

the requirements for an equivalent level of safety pursuant to Section 333 based on the 

small size, light weight, relatively slow speed, and use in controlled environments on 

private land, as described previously in this petition. In Exemption No. 11138, the FAA 

stated that the Secretary of Transportation has determined that a member of the DJI 

Phantom 2 family, the Phantom 2 Vision+ meets the statutory conditions of Section 333, 

considering the size, weight, speed, and limited operating area associated with the aircraft 

and its operation. See Exhibit 10 at 11. 

Equivalent level of safety: SkyShot Production’s proposed exemption meets the 

requirements for an equivalent level of safety of this section, pursuant to Section 333, 

based on the following factors: 

• Small size: the DJI Phantom 2 has a diagonal length of 350 millimeters, 13.77 

inches. 

• Light weight: 2.9 lbs. 
• Relatively slow speed: the PIC will limit the sUAS’s speed to 20 knots (23 

miles 

per hour). 

• Operational capacity: currently, the DJI Phantom 2 can operate for 25 minutes. 

Flights will be terminated when 25% of the battery life remains. The DJI Phantom 

2 can travel no more than 1,000 meters, 3280.84 feet, from the receiver. 

• Proximity to airports: SkyShot Productions will only operate in Class G 

airspace, and will notify ATC and the local FSDO prior to operations, as 

described previously. 

• Proximity to populated areas SkyShot Productions will work with the local 

Flight Standards District Offices to determine which areas to avoid during flights. 

Local FSDO may carve out areas indicated as yellow in the sectional chart and 

allow SkyShot Productions to fly in these specifically designated carve-out areas. 

• Operation within visual line of sight: The PIC will always fly the sUAS within 

its 

line of sight. 

• Location:SkyShot Productions will operate in rural, suburban, with low 

population density. 

• Altitude: no more than 200 feet AGL, but the majority of flights are anticipated 

at no more than 100 feet AGL. 

Restricted area in which the sUAS will be operated: as described above, prior to 

the day of filming, the flight crew will visit with neighbors to inform them of the 

filming over the consenting landowner’s property. During filming, which will 

occur in rural areas, the flight crew will set out cones to mark the “home area” for 

the sUAS, and will monitor the area to make sure no one comes into the flight 

area. Should any nonparticipating individual enter the flight area, operations will 

immediately cease. See Exhibit 10 at 19. 

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft 

engines, propellers, appliances, or component parts for return to service after 

maintenance, preventive maintenance, rebuilding, or alteration. 

SkyShot Productions requests an exemption from 14 C.F.R. 43.7. This part provides, 

inter alia, that the holder of a mechanic certificate or a repair station certificate may 

approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for 

return to service. As described previously, SkyShot Productions’s flight crew will be 

capable to repair and maintain the DJI Phantom 2 to meet an equivalent level of safety of 

this section. 

Equivalent level of safety: The nature of the sUAS is that of a model aircraft, and the 

operators of SkyShot Productions who will maintain and when necessary repair the sUAS 

will conduct inspections and maintenance based on maintenance guidelines provided by 

the manufacturer of the sUAS, DJI. See Exhibits 1-5. The capabilities of these operators 

to maintain and repair the sUAS will be listed in the operator’s manual and meet the 

requirements for an equivalent level of safety pursuant to Section 333 for the type of 

sUAS, its intended use, and the rural operating environment. 

C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections 

conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter. 
SkyShot Productions requests an exemption from 14 C.F.R. 43.11. This part provides, 

inter alia, that maintenance record entries be maintained and for the listing of 

discrepancies and placards by inspectors. The sUAS, due to its small size, does not have 

room for placards to be placed in or on it and no inspections for sUAS have been certified 

by FAA at the present time. 

Equivalent level of safety: SkyShot Productions will keep log books of all maintenance 

and repairs at the ground station, as envisioned in the FAA Memorandum subject, 

“Interpretation regarding whether certain required documents may be kept at an 

unmanned aircraft’s control station,” dated August 8, 2014. See Exhibit 8. This request 

provides an equivalent level of safety as 14 C.F.R. 43.11 because the documentation will 

be at the ground station with the PIC, where it will be useable in case of an emergency, 

rather than with the sUAS which could be up to 1,000 meters from the operator. 

D. 14 C.F.R. 45.11: Marking of products. 

SkyShot Productions requests an exemption from 14 C.F.R. 45.11. This part provides, 

inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, 

engines, or propellers with an approved fireproof identification plate. The sUAS, due to 

its small size, does not have room for fireproof placards to be placed in it. Any required 

placards could become hazardous, due to the additional weight and strain placed on the 

sUAS. Any additional weight or placards on the 2.9 lbs. sUAS could create a risk, due to 

the very small size and nature of the DJI Phantom 2. 

Equivalent level of safety: SkyShot Production’s PIC and VO will keep information 

related to the DJI Phantom 2, including the user manual, at the ground control station and 

affix its N-Number, once obtained from the FAA Registration Office, on the “arms” of 

the sUAS as large as practicably possible. This exemption provides an equivalent level of 

safety to 14 C.F.R. 45.11 because the relevant documentation containing the serial 

number will be at the ground station with the PIC, where it will be useable in case of an 

emergency, rather than with the sUAS. In addition, the fuselage is marked with “DJI,” the 

manufacturer of the sUAS. 

E. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft 

SkyShot Productions requests an exemption from 14 C.F.R. 45.27. This part provides, 

inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on 

both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The 

sUAS, due to its small size, does not have a cabin, fuselage, boom or tail to display the 

marks required by §45.23. 

Equivalent level of safety: Once SkyShot Productions receives its N-Number, it will 

display these marks on the “arms” of the aircraft as large as practicably possible. This 

exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUAS 

will be registered with the FAA Aircraft Registration Branch. In the event of incident, the 

sUAS will be traceable to SkyShot Productions. 

13 

F. 14 C.F.R. 45.29: Size of marks 

SkyShot Productions requests an exemption from 14 C.F.R. 45.27. This part provides, 

inter alia, at subpart (3) that the registration marks for rotorcraft must be at least 12 

inches high. The sUAS, due to its small size, does not have any surface area large enough 

to display marks anywhere near 12 inches high. 
Equivalent level of safety: SkyShot Productions will affix its registration number as 

large as practicably possible on its “arms” once it obtains the N-Number. This exemption 

provides an equivalent level of safety to 14 C.F.R. 45.29 because the sUAS will be 

registered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS 

will be traceable to SkyShot Productions. 

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

The FAA has previously stated that no exemption is required for a member of the DJI 

Phantom 2 family. Exhibit 8 at 17. SkyShot Productions requests the same determination 

to be made for its DJI Phantom 2. 

Alternatively, SkyShot Productions requests an exemption from 14 C.F.R. 91.7(a). 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 standard will exist for determining airworthiness. 

Equivalent level of safety: SkyShot Productions will keep the DJI Phantom 2’s 

maintenance and safety information at the ground station, where it will be readily 

accessible to the PIC and VO before, during, and after operations. This exemption 

provides an equivalent level of safety as 14 C.F.R. 91.7(a) because the PIC will be able to 

make the determination of whether the sUAS is in an airworthy mechanical and electrical 

condition, in accordance with 14 C.F.R. 91.7(b). 

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

requirements. 

The FAA has previously stated that no exemption is required for a member of the DJI 

Phantom 2 family. Exhibit 10 at 17. SkyShot Productions requests the same 

determination to be made for its DJI Phantom 2. 

Alternatively, SkyShot Productions requests an exemption from 14 C.F.R. 91.9(b)(2). 

This part provides: 

"(b) No person may operate a U.S.-registered civil aircraft... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof." 

First, there does not currently exist a method of approving manuals for sUAS. Second, 

given the size and configuration of the sUAS, there is no space to carry such a flight 

manual on the aircraft. In addition, carrying the manual on the aircraft would be 

pointless, since there is no pilot or other person on board who could read or use it. On 

August 8, 2014, the FAA issued a memorandum entitled “Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft’s control 

station.” This document stated, in part “maintaining these documents at the pilot’s control 

station would meet the intent of the rule as the pilot would be able to produce the 

documents for his or her own information or to an FAA inspector.” See Exhibit 9. 

Equivalent level of safety: SkyShot Productions will keep its flight manual at the ground 

station, where both the PIC and VO can access it. An equivalent level of safety to 14 

C.F.R. 91.9(b)(2) is provided because the intent of this rule – the pilot having access to 

this material during flight – is met. 
I. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard 

requirements. 

SkyShot Productions requests an exemption from 14 C.F.R. 91.9(c). This part provides: 

"(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with part 45 of this chapter." 

As stated above, SkyShot Productions will obtain an N-Number from the FAA 

Registration Office and the sUAS, due to its small size, does not have room to contain 

fireproof placard or to display aircraft marks in a conventional size. However, once 

SkyShot Productions obtains an N-Number, it will place the number on the “arms” of the 

aircraft as large as practicably possible. 

Equivalent level of safety: SkyShot Productions will obtain its N-Number from the FAA 

Registration Office and affix it to the “arms” of the aircraft as large as practicably 

possible. An equivalent level of safety to 14 C.F.R. 91.9(c) is met because the sUAS will 

be registered with the FAA and identifiable in the event of an incident. 

J. 14 C.F.R. 91.103(b)(2): Preflight action. 

SkyShot Productions requests an exemption from 14 C.F.R. 91.103(b)(2) to the extent 

that is applicable. This part provides: 

"Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—... (b) For 

any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: ... (2) For civil aircraft other than those specified in 

paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, 

relating to aircraft performance under expected values of airport elevation and runway 

slope, aircraft gross weight, and wind and temperature." 

SkyShot Production’s PIC in fact will, before beginning a flight, become familiar with all 

available information concerning that flight, including the aircraft performance under 

expected elevations, the gross weight of the aircraft (which will be no more than 2.9 lbs.), 

and the wind and temperature. As the flights of the sUAS will not be at airports the 

information required of Part 91.103(b)(2) does not apply. 

Equivalent level of safety: SkyShot Productions shall perform preflight operations as 

outlined previously in this petition, and flights will not be at airports. An equivalent level 

of safety to 14 

15 

C.F.R. 91.103(b)(2) will be met because the PIC will become familiar with the conditions 

prior to the flight, including the aircraft performance under expected elevations, the gross 

weight of the aircraft (which will be no more than 2.9 lbs), and the wind and temperature. 

K. 14 C.F.R. 91.105: Flight crewmembers at stations. 

SkyShot Productions requests an exemption from 14 C.F.R. 91.105 since this part is not 

applicable due to the sUAS carrying no flight crewmembers. 

Equivalent level of safety: SkyShot Productions will not operate the aircraft unless 

someone is at the controls at all times, and each flight will be manually flown, with the 

exception of the DJI Phantom 2’s automated safety features. This will provide an

equivalent level of safety to 14 C.F.R. 91.105 because the flight crew will be at their 

stations at all times during the flight. The stations will not be on the aircraft but on the 

ground. 

L. 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations. 
SkyShot Productions requests an exemption from 14 C.F.R. 113(b) to the extent that it 

applies to overhead aircraft operating at or above 500 feet AGL as the sUAS will be 

operating no higher than 400 feet AGL. This part provides: 

“(b): General. When weather conditions permit, regardless of whether an operation is 

conducted under instrument flight rules or visual flight rules, vigilance shall be 

maintained by each person operating an aircraft so as to see and avoid other aircraft. 

When a rule of this section gives another aircraft the right-of-way, the pilot shall give 

way to that aircraft and may not pass over, under, or ahead of it unless well clear." 

For example, if another aircraft is operating overhead at 10,000 feet AGL there is no 

danger posed to that other aircraft if the sUAS is operating under it or ahead of it at or 

beneath 400 feet AGL. Despite this, should another aircraft enter the area in which 

SkyShot Productions is operation, because the flight will be within his line of sight, the 

PIC will be able to give right of way to that aircraft. 

Equivalent level of safety: SkyShot Productions will operate its sUAS to see and avoid 

and give way to other aircraft that should enter airspace at or below 400 feet AGL, and 

will give right-of-way to manned aircraft. All flights will be in class G airspace and the 

majority of flights will be at no more than 100 feet AGL, which will create a very slim 

chance that SkyShot Production’s operations will interfere with a manned aircraft’s 

flight. This will provide an equivalent level of safety to 14 C.F.R. 91.113(b) because the 

sUAS has significantly greater mobility than a much larger, manned aircraft. As a result, 

the PIC will be able to react and respond much more quickly than the other pilot. 

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

SkyShot Productions requests an exemption from 14 C.F.R. 91.119 subpart (c). This 

regulation provides: 

"Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes... 

(c) Over other than congested areas. 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.”

SkyShot Productions will not operate the sUAS any higher than 200 feet AGL. 

Equivalent level of safety: SkyShot Productions will operate the sUAS no higher than 

400 feet AGL, and it is anticipated that the majority of operations will be no higher than 

100 feet AGL. SkyShot Productions will not operate in congested areas, and will work 

with the local FSDO when planning operations. SkyShot Production’s flight crew will 

make a safety assessment prior to each operation, and only operate after it determines that 

there is no undue hazard present. Exhibit 8 at 19. 

The 400 feet AGL maximum will provide an equivalent level of safety to 14 C.F.R. 

91.119(c) because, since 1981 with AC 91-57, this height has been an operating standard 

for model aircraft. Additionally, in Section 334(c)(2)(C), Congress determined that sUAS 

operated by public agencies flying sUAS the size of and larger than SkyShot 

Production’s DJI Phantom 2 could fly up to 400 feet AGL. 

N. 14 C.F.R. 91.121: Altimeter Settings 

SkyShot Productions requests an exemption from 14 C.F.R. 91.121. This Part provides 

guidelines for altimeter use in maintaining the cruising altitude or flight level of the 

aircraft. SkyShot Productions is not requesting a general exemption from the requirement 
that its sUAS have an Altimeter. The DJI Phantom 2’s flight controller will have an 

internal measurement unit (“IMU”). The IMU has a built-in internal sensor and a 

barometric altimeter that measures both attitude and altitude. See Exhibit 1, Appendix B, 

page 5. Rather, SkyShot Productions requests an exemption from the requirement to set 

its altimeter to a station along the route, of out of an airport, because the DJI Phantom 2 is 

not traveling point-to-point and is limited in the distance it can travel from the PIC. 

Additionally, SkyShot Productions will not be flying into or out of an airport. 

Equivalent level of safety: The requested exemption provides an equivalent level of 

safety to 14 C.F.R 91.121 because SkyShot Productions will not operate the sUAS above 

400 feet AGL in a sustained cruising flight mode such as a manned aircraft will typically 

fly. The PIC will at all times be controlling the maximum height of the sUAS through the 

telemetry features of the DJI controller. Additionally, the sUAS will be operated within

the line of sight of the PIC. The FAA has previously granted this exemption for similar 

proposed operations. See Exhibit 10. 

O. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. 

The sUAS SkyShot Productions will fly is powered by electricity, using lithium polymer 

batteries that currently have a flight limit of approximately no more than 25 minutes. (See 

Exhibits 1 and 10). Therefore, due to the limitations of the batteries, it is currently 

impossible to comply with Part 91.151. However, the sUAS will be operated in a manner 

with at least the equivalent level of safety as that of a manned aircraft complying with 

Part 91.151. 

Operation of an sUAS with less than 30 minutes of reserve fuel does not engender the 

type of risks that Section 91.151(a) was intended to alleviate. During the entire flight, the 

PIC will always have a visual line of sight of the sUAS and the VO will be monitoring 

the battery life via the telemetry display on the laptop at the ground station. The sUAS 

will always have enough power to land safely, given the minimum level of reserve 

capacity of the batteries. 

SkyShot Productions will limit flights to 75% of battery capacity. With the battery 

SkyShot Productions currently uses, the 75% point occurs at 18 minutes, leaving 7 

minutes for the sUAS to reach the planned landing zone. This amount of time will be 

more than sufficient for the PIC to safely return to and land in the “home area.” As 

battery power increases, the number of minutes the sUAS can operate before reaching the 

75% mark will also increase. As new batteries are obtained and put into use, SkyShot 

Productions will continue to terminate flights after 75% of battery power has been used. 

Applicant believes that an exemption from 14 CFR §91.151(a) is consistent with the 

scope of similar exemptions already granted to other operations. Exhibit 10. 

Equivalent level of safety: SkyShot Productions will limit flights 75% of battery power. 

The proposed exemption meets an equivalent level of safety to 14 C.F.R. 91.151 because, 

given the limitations on SkyShot Production’s proposed operations and the location of 

those operations, a reduced minimum power reserve for flight in daylight VFR conditions 

is reasonable. 

P. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required. 

The FAA has previously determined that exemption from 14 C.F.R. 91.203(a) and (b) is 

not necessary. See Exhibit 10 at 17. 

Alternatively, SkyShot Productions requests an exemption from 14 C.F.R. 91.203(a) and 

(b). This section provides in part:
“(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate... 

(2) An effective U.S. registration certificate issued to its owner... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” 

First, there are currently no procedures in effect for providing airworthiness certificates 

for sUAS. However, as a condition to the approval of exemption, SkyShot Productions 

will display its N-Number, once received, on the sUAS, and the operator will have, at the 

ground station, the user manual for the DJI Phantom 2. 

Second, the sUAS SkyShot Productions will use the DJI Phantom 2, which has an 

equivalent level of safety as a manned aircraft with an airworthiness certificate. Please 

refer to Exhibit 10, Exemption No. 11138, as SkyShot Production’s DJI Phantom 2 is in 

the same sUAS family as the DJI Phantom 2 Vision+, which was the subject of that 

exemption. This sUAS provides a number of safety features, including the automatic 

return to home failsafe discussed in detail above. 

Because of the use of GPS with the sUAS, the operator will set the initial location of 

flight takeoff ("home position") and if the radio control link is broken, the autopilot 

system will recognize this broken control link and cause the sUAS to automatically return 

to the home position as recorded by the GPS instrumentation. Exhibits 1-7. Additionally, 

because the sUAS team will mark off an area with traffic cones that has a 20 ft. radius, 

approximately 30 ft. from the operators that will be used as the “home position” for the 

sUAS to return, no one will be standing in the way of the path. 

These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under Subpart H. 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 payload. 

In the restricted environment and under the conditions proposed, operation of the sUAS 

will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate but without the restrictions and conditions proposed. SkyShot 

Productions will not accept assignments from clients that would take place in Class B, C, 

D, or E airspace. SkyShot Productions will avoid flying over congested and populated 

areas and will work with local FSDO to avoid these areas when planning operations. 

Equivalent level of safety: The sUAS to be operated hereunder is 2.9 lbs. inclusive of 

batteries and technical payload, carries neither a pilot nor passengers, and carries no 

explosive materials or flammable liquid fuels. The sUASs operating under this exemption 

will be tightly controlled and monitored by the operator and the observer, and in 

compliance with local public safety requirements, to provide security for the area of 

operation. The FAA will have advance notice of all operations because SkyShot 

Productions will notify both ATC and the local FSDO prior to operations, as described 

previously in this petition. Granting the proposed exemption will achieve an equivalent 

level of safety to 14 C.F.R. 91.203(a) and (b) because of the small size of the sUAS and 

the operational limits set out above. 
Q. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use 

This section requires that installed Air Traffic Control (ATC) transponder equipment 

must meet specific performance and environmental requirements, and aircraft must be 

equipped with an operable coded radar beacon transponder. 

There are presently no known commercially available ATC transponders that meet the 

payload requirements of a sUAS and are available at reasonable cost. However, because 

the sUASs used by SkyShot Productions will not be flying into or near airports, and will 

fly no higher than 200 feet AGL, there is very low risk of collision with any manned 

aircraft. In addition, because there will be no need to have contemporaneous 

communication with ATC Control, due to the short distances, short flight times, and 

restricted altitude the sUASs will operate within, SkyShot Productions requests an 

exemption from this section. Additionally, the sUAS is too small to contain ATC 

transponder equipment in any form factor that is known to be available commercially. 

Equivalent level of safety: An equivalent level of safety to 14 C.F.R. 91.215 will be met 

because SkyShot Productions will not fly its sUAS into or near airports, and all 

operations will be below 200 feet AGL, so there is very low risk of collision with any 

manned aircraft. SkyShot Productions will contact local ATC before operations to issue a 

NOTAM, and the local FSDO with its flight plan, as described previously in this petition. 

SkyShot Productions also give right of way to any manned aircraft that do appear. 

R. 14 C.F.R. 91.403: General 

This section requires that the owner or operator of an aircraft is primarily responsible for 

maintaining that aircraft in an airworthy condition. SkyShot Productions will adhere to 

this requirement. However, this Section also limits maintenance to that “prescribed in this 

subpart and other applicable regulations, including part 43 of this chapter.” Because of 

this limitation, and because of the exemptions under Part 43 requested above, SkyShot 

Productions requests an exemption from this Section. 

This exemption meets the requirements for an equivalent level of safety pursuant to 

Section 333 based on the small size, light weight, relatively slow speed, and use in 

controlled rural environments on private, secured land, as described previously in this 

petition. 

Equivalent level of safety: To achieve an equivalent level of safety to 14 C.F.R. 91.403, 

SkyShot Productions will maintain its sUAS in an airworthy condition and adhere to all 

manufacturer requirements for inspecting and maintaining the DJI Phantom 2. SkyShot 

Productions will keep records of maintenance to the sUAS, and these records will be 

available to the PIC and VO before, during, and after operations of the sUAS. 

S. 14 C.F.R. 91.405 (a) and (d): Maintenance Required 

This section requires that aircraft be inspected as prescribed by Section E, 14 C.F.R. 

§§91.401-91.421. As shown below, SkyShot Productions is applying for an exemption 

for these sections, due to the fact that its operators will inspect the sUAS prior to each 

flight and keep maintenance records of all parts that are replaced, in accordance with 

DJI’s instructions. Because the Sections discussed below are concerned with manned 

aircraft, and as such have inspection requirements designed for the safety of passengers, 

they are inapplicable to SkyShot Productions. 

SkyShot Productions is also applying for an exemption to subpart (d) of this section, 

which requires a placard to be installed and references §43.11. As noted previously, 
SkyShot Productions requests an exemption to the placard requirement, because, due to 

the small size of the sUAS, there is no room to place the placard. 

Despite the requested exemption from subparts (a) and (d) of this section, SkyShot 

Productions will follow subparts (b) and (c) of this subpart. 

Equivalent level of safety: To achieve an equivalent level of safety to 14 C.F.R. 

91.405(a) and (b), SkyShot Productionswill keep logbooks detailing all maintenance and 

repairs to the sUAS. The logbooks will be available to the PIC and VO before, during, 

and after sUAS operation. Prior to conducting post-maintenance operations, the flight 

crew will conduct a test flight to ensure that the sUAS functions properly. The FAA has 

previously determined that following the manufacturer’s requirements for maintenance, 

inspection, and record keeping are sufficient to ensure that safety is not adversely 

affected. Exhibit 10 at 13. 

20 

T. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, 

rebuilding, or alteration 

This section requires that any aircraft which “has undergone maintenance, preventative 

maintenance, rebuilding, or alteration unless . . . [i]t has been approved for return to 

service by a person authorized under § 43.7 of this chapter . . ..” 

However, SkyShot Productions has requested an exemption from §§ 43.7 and 43.11 as 

described previously. The capability of the operators to maintain and repair the sUAS 

meets the requirements for an equivalent level of safety pursuant to Section 333 for both 

the type of sUAS, its intended use, and the rural operating environment. Additionally, 

due to the small size of the sUAS, there is no room to place inspection placards. 

Therefore, because SkyShot Productions has requested an exemption from 43.7 and 

43.11, SkyShot Productions respectfully requests an exemption from 91.407. The PIC, 

who holds a commercial pilot’s certificate, will conduct maintenance on the sUAS and 

keep logs of the battery cycle and repairs needed on the body or the propellers of the DJI 

Phantom 2. 

Equivalent level of safety: The proposed exemption will meet an equivalent level of 

safety to 14 C.F.R. 91.407 because SkyShot Productions will regularly inspect and 

maintain its sUASs in accordance with the DJI operator manual, and keep detailed 

inspection and maintenance records that will be available to the PIC and VO before, 

during, and after operations. Prior to conducting post- maintenance operations, SkyShot 

Productionswill conduct a test flight to ensure that the sUAS functions properly. 

U. 14 C.F.R. 91.409: Inspections 

This section lays out specific requirements for inspections of aircraft. SkyShot 

Productions respectfully requests an exemption from these requirements because they are 

intended to maintain the safety of manned aircraft significantly larger and capable of 

significantly longer flights than is sUAS. SkyShot Production’s pre-flight and post-flight 

inspections meet or exceed the level of safety achieved by adherence to 14 C.F.R. 91.409. 

Equivalent level of safety: As discussed above and in Appendix D, SkyShot Productions 

has an inspection procedure that provides an equivalent level of safety to 14 C.F.R. 

91.409. Before and after each flight, the flight crew will conduct an inspection of the 

sUAS as described previously. 

V. 14 C.F.R. 91.417: Maintenance records 
SkyShot Productions respectfully requests an exemption from this Section, as it is only 

applicable for aircraft with an airworthiness certificate. Because SkyShot Productions 

will not have an airworthiness certificate, this Section is inapplicable. 

Equivalent level of safety: The requested exemption will meet an equivalent level of 

safety to 14 C.F.R. 91.417 because SkyShot Productions will keep detailed maintenance 

records on every part as it is replaced, including but not limited to propellers, batteries, 

and electrical components. The detailed maintenance records will be accessible to the 

PIC and the VO before, during, and after operations.