U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

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, Mariucci Video Productions, seeks an exemption from Federal Aviation Regulations 

(“FARs”) detailed below for the DJI Phantom 2 Vision Plus, and the Phantom 3, quad copters

manufactured by DJI-Innovations.

The requested exemption would support an application for a commercial Certificate of Authorization to

use the systems to support aerial videography and photography. The DJI Phantom Vision 2 Plus system 

consists of a lightweight battery operated aircraft, a tablet-based ground control station and/or RC 

Controller, and associated communications equipment. The aircraft carries an onboard geo-referenced 

gimbaled camera that allows it to obtain photography and videography. 

We are family owned and have been in the video production business for 25 years. With the advances in 

technology in our field over the last 25 years, the easy to use, lightweight aerial video systems such as 

the DJI Phantom has given us the ability to capture footage that was once impossible or impractical due 

to the high cost. We are seeking an exemption so we can offer our customers new vantage points from 

the air. We plan on using the DJI system to get footage that we were unable to provide before. A few of 

the things we would be using the DJI system for include weddings, real estate, property assessments, 

sporting events, and scenic aerial shots for tourism videos. We are located on the Iron Range in 

Northern Minnesota were the main economic industry is mining. In the future we would like to be able 

to provide aerial imagery of their operations to assist in safety and productivity. 

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground-based Visual
Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for

UAS" with the following additional restrictions:

- All operations will occur in Class G airspace at no more than 400' AGL

- Operations will only be conducted with permission from the appropriate land owner

- All required permits will be obtained from state and local government prior to operation

- The aircraft will not be operated over populated areas as defined on FAA sectional maps

- The aircraft will not be operated at air shows or over an open-air assembly of people

- The aircraft will not be operated over heavily trafficked roads

- The aircraft will not be operated within 5 NM of a public airport or heliport

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight at no greater than 1/4 NM of the PIC at all time

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation a

minimum of 72 hours before any planned flight activity

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training. We submit that the combination of 

the aircraft's light weight, the autopilot’s demonstrated flight performance, fully qualified flight crew 

and strict operation under the guidelines established in 8900.227, the FAA can have confidence that the 

operation will have an equivalent or greater level of safety of manned aircraft performing the same 

mission.

The name and contact information of the applicant:

Mariucci Video Productions

Hugo Mariucci

218-741-3850

hugomvp@rangenet.com

The regulations from which the exemption are requested below:
- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level 

of safety. We look forward to working with your office. Please contact us at any time if you require

additional information or clarification.

Sincerely,

Hugo Mariucci

Owner Mariucci Video Productions