DOROSH	DOCUMENTARIES,	LLC.

-January	19,	2016-

U.S.	Department	of	Transportation	•	Docket	Management	System

1200	New	Jersey	Ave.,	SE	•	Washington,	D.C.	20590

Re:

Petition	of	Dorosh	Documentaries,	LLC	for	Exemption	from	Certain	

Federal	Aviation	Regulations to	Operate	Unmanned	Aircraft	Systems	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act

To	Whom	It	May	Concern:

Pursuant	to	Section	333	of the	FAA	Modernization	and	Reform	Act	

("FMRA")	and	14	C.F.R.	part	11,	Dorosh	Documentaries,	LLC	hereby	

petitions	the	Federal	Aviation	Administration	("FAA")	for	exemption	

from	14	C.F.R.	§§	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,	91.15l(a)(l),	91.405(a),	

91.407(a)(l),	91.409(a)(l)	and	(2),	and	91.417(a)	and	(b),	and	any	

other	rules	the	FAA	deems	necessary,	to	enable	Dorosh	

Documentaries,	LLC to	operate	unmanned	aircraft	systems	("UAS")	

for	aerial	data	collection.	Specifically,	Dorosh	Documentaries,	LLC	

seeks	to	operate	UAS	for	newsgathering,	commercial	production,	

promotional	video,	and	special	events	such	as	sporting	events,	

wedding	ceremonies	and	receptions,	using	the	DJI	Phantom	3.		

Because	this	petition	is	similar	in	all	material	respects	to	previouslygranted	Section	333	petitions,	Dorosh	Documentaries, LLC	requests	

expedited	approval	pursuant	to	the	FAA's	summary	grant	process.

I.	PROPOSED	OPERATIONS	AND	PUBLIC	INTEREST	BENEFITS

Dorosh	Documentaries,	LLC is	a	television	and	post-production	

company	that	specializes	in	marketing,	production,	events	

management	and	distribution	company.		Dorosh	Documentaries,	

LLC has	been	outsourced	for	aerial	footage	from	the	Pittsburgh	

Pirates,	Pittsburgh	Penguins,	Root	Sports,	NCAA,	Pitt,	Fox	Sports,	

and	many	other	companies	for	the	purposes	of	marketing	their	
teams,	school,	and	company.		Dorosh	Documentaries,	LLC	seeks	to	

use	UAS	to	conduct	aerial	data	collection	that	will	serve	a	variety	of	

functions	including	newsgathering,	commercial	production,	

promotional	video,	and	special	events	such	as	sporting	events,	

wedding	ceremonies	and	receptions.		Grant	of	this	petition	will	

enable	Dorosh	Documentaries,	LLC	to	better	serve	its	viewers	across	

the	country,	as	Dorosh	Documentaries,	LLC	will	be	able	to	obtain	

key	aerial	footage	for	promotional	videos	and	other	content	and	

operate	its	business	more	safely,	efficiently	and	effectively	than	ever	

before.

In	addition	to	fostering	significant	public	interest	benefits,	Dorosh	

Documentaries,	LLC operations	will	carry	minimal	risk.		Dorosh	

Documentaries,	LLC	is	committed	to	the	safe	operation	of	its	UAS,	

and	will	adhere	to	stringent	operating	conditions	in	conformity	with	past	

grants	of	exemption.	These	conditions	ensure	that	Dorosh	

Documentaries,	LLC will	operate	safely	in	the	national	airspace,	

mitigate	the	risks	of	harming	other	aircraft	or	people	or	property	on	the	

ground,	and	present	no	threat	to	national	security.	Adhering	to	these	

parameters,	Dorosh	Documentaries,	LLC will	be	able	to	safely	and	

effectively	operate	its	UAS	to	the	benefit	of	its	viewers,	crewmembers,	

and	the	general	public.

II.	UAS

Dorosh	Documentaries,	LLC	requests	an	exemption	to	operate	the	DJI	

Phantom	3	which	is	well	below	55	pounds	including	payload.	Through	

the	Section	333	exemption	process,	the	FAA	has	authorized	use	of	all	

UAS	for	which	exemption	is	requested	herein.	

III.	REQUEST	FOR	SUMMARY	GRANT

Dorosh	Documentaries,	LLC	requests	that	the	FAA	issue	a	summary	

grant	of	exemption	pursuant	to	the	agency's	expedited	summary	grant	

process.		Dorosh	Documentaries,	LLC	will	adhere	to	operating	
parameters	that	will	offer	the	same	level	of	safety	as	the	conditions	the	

FAA	currently	requires	in	its	summary	grants.

IV. APPLICANT	INFORMATION

The	name	and	contact	information	of	the	applicant	is:

Nazari	Dorosh

CEO,	Dorosh	Documentaries

5317	Fieldcrest	dr

Pittsburgh,	PA	15236

Regulations	from	which	exemption	is	requested:

14	C.F.R.	§§	61.23(a)	and	(c);

14	C.F.R.	§§	61.101(e)(4)	and	(5);	

14	C.F.R.	§	61.113(a);	

14	C.F.R.	§	61.315(a);	

14	C.F.R.	§	91.7(a);	

14	C.F.R.	§	91.119(c);	

14	C.F.R.	§	91.121;	

14	C.F.R.	§	91.151(a)(l);

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).

V.	OPERATING	PARAMETERS

Dorosh	Documentaries,	LLC	will	adhere	to	the	following	operating	
parameters	when	operating	UAS	pursuant	to	a	grant	of	the	

requested	exemption:

1. Operations	will	be	conducted	using	the	DJI	Phantom	3

2. The	UAS	will	not	be	operated	at	a	speed	exceeding	87	knots	(100	

miles	per	hour),	at	an	altitude	greater	than	400	feet	above	ground	

level,	or,	when	visibility	is	less	than	3	statute	miles,	less	than	500	

feet	below	or	2,000	feet	horizontally	from	a	cloud.	All	operations	

will	be	conducted	during	the	day	under	visual	meteorological	

conditions.

3. All	operations	will	be	conducted	in	accordance	with	a	Cettificate	of	

Waiver	or	Authorization	("COA'').

4. All	operations	will	use	a	pilot-in-command	("PIC")	and	a	visual	

observer	("VO"),	and	the	UAS	will	remain	within	the	visual	line	of	

sight	of	the	PIC	or	the	VO	at	all	times.	The	PIC	will	maintain	VLOS	

capability	and	the	ability	to	communicate	verbally	with	the	VO	at	all	

times.

5. The	PIC	will	hold	an	airline	transport,	commercial,	private,	

recreational,	or	sport	pilot	certificate,	as	well	as	an	FAA	airman	

medical	certificate	or	a	valid	U.S.	driver's	license.	The	PIC	will	meet	

the	flight	review	requirements	specified	in	14	C.F.R.	§	61.56	in	an	

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

6. Dorosh	Documentaries,	LLC will	ensure	prior	to	operation	that	the	

PIC	has	demonstrated	the	ability	to safely	operate	the	UAS	in	a	

manner	consistent	with	how	the	UAS	will	be	operated	under	this	

exemption,	including	evasive	and	emergency	maneuvers	and	

maintaining	appropriate	distances	from	persons,	vessels,	vehicles	

and	structures.	PIC	qualification	flight	hours	and	currency	will	be	

logged	in	a	manner	consistent	with	14	C.F.R.	§	61.51(b).

7. Dorosh	Documentaries,	LLC operating	documents	will	be	accessible	

during	UAS	operations	and	made	available	to	the	Administrator	

upon	request.

8. Prior	to	each	flight,	the	PIC	will	conduct	a	pre-flight	inspection	and	

determine	the	UAS	is	in	a	condition	for	safe	flight.	If the	inspection	

reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	

UAS	will	not	be	operated	until	the	necessary	maintenance	has	been	

performed	and	the	UAS	is	found	to	be	in	a	condition	for	safe	flight.
9. Any	UAS	that	has	undergone	maintenance	or	alterations	that affect	

the	UAS	operation	or	flight	characteristics,	e.g.,	replacement	of	a	

flight	critical	component,	will	undergo	a	functional	test	flight	prior	

to	conducting	further	operations	under	this	exemption.

10.	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	

the	UAS	operation	or	flight	characteristics,	e.g.,	replacement	of	a	

flight	critical	component,	will	undergo	a	functional	test	flight	prior	

to	conducting	further	operations	under	this	exemption.

11.	Dorosh	Documentaries,	LLC will	follow	the	UAS	manufacturer's	

maintenance,	overhaul,	replacement,	inspection,	and	life	limit	

requirements,	as	well	as	safety	bulletins,	for	the	aircraft	and	aircraft	

components.

12.	The	PIC	will	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	

emergencies,	and	will	yield to	all	manned	aviation	activities.

13.	Dorosh	Documentaries,	LLC will	register	and	mark	its	UAS	in	

accordance	with	14	C.P.R.	parts	47	and	45.

VI.	THE	FAA’S	AUTHORITY	TO	GRANT	THIS	PETITION

The	FAA	has	authority	to	grant	the	exemption	requested	herein	

under	the	FMRA	and	the	Federal	Aviation	Act.	Section	333	of	the	

FMRA	deals	specifically	with	integrating	UAS	into	the	national	

airspace,	and	directs	the	Secretary	of	Transportation	to	determine	

which	UAS,	"as	a	result	of	their	size,	weight,	speed,	operational	

capability,	proximity	to	airports	and	populated	areas,	and	operation	

within	visual	line	of	sight	do	not	create	a	hazard	to	users	of	the	

national	airspace	system	or	the	public	or	pose	a	threat	to	national	

security."3	Section	333	further	directs	the	Secretary	to	"establish	

requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	

national	airspace	system."4	The	Federal	Aviation	Act	authorizes	the	

Administrator	of	the	FAA	to	grant	exemptions	from	regulations	

prescribed	under	certain	provisions	of	the	Act	where	such	

exemptions	are	in	the	public	interest.5	Part	11	of	the	Federal	Aviation	

Regulations	governs	the	FAA's	exemption	process	and	

requirements.6	The	FAA	has	granted	more	than	1,100	exemptions	to	
date	pursuant	to	its	Section	333	and	exemption	authority,	enabling	

commercial	UAS	operations	in	a	wide	variety	of	industries.

3	 Pub.	L.	No.	112-95,	126	Stat.	75-76	(codified	as	a	Note	to	49	U.S.C.	§	40101).

4	 Id

5	 49	U.S.C.	§	44701	(f)	("The	Administrator	may	grant	an	exemption	from	a	

requirement	of	a	regulation	prescribed	under	subsection	(a)	or	(b)	of	this	section	or	

any	of	sections	44702-44716	of	this	title	if	the	Administrator	finds	the	exemption	is	

in	the	public	interest.").

6 See	49	C.F.R.	Part	I	I.

VII.	SUMMARY	TO	BE	PUBLISHED	IN	THE	FEDERAL	REGISTER

Should	the	FAA	determine	that	publication	in	the	Federal	Register	is	

required,	Dorosh	Documentaries,	LLC offers	the	following	summary	

pursuant	to	section	11.81	of	the	FAA's	rules:7

Petitioner:	Dorosh	Documentaries,	LLC

Sections	o	f	14	C.	FR.	Affected:	14 C.F.R.	§§	61.23(a)	and	(c);	14	C.F.R.	§§	

61.101(e)(4)	and	(5);	14	C.F.R.	§	61.113(a);	14	C.F.R.	§	61.315(a);	14	

C.F.R.	§	91.7(a);	14	C.F.R.	§	91.119(c);	14	C.F.R.	§	91.121;	14	C.F.R.	§	

91.15l(a)(l);	14	C.F.R.	§	91.405(a);	14	C.F.R.	§	91.407(a)(l);	14	C.F.R.	§§	

91.409(a)(1)	and	(2);	14	C.F.R.	§§	91.417(a)	and	(b).

Description	of	Relief	Sought:	Petitioner	seeks	relief	from	the	

requirements	of	14	C.F.R.	§§	61.23(a)	and	(c);	14	C.F.R.	§§	61.101(e)(4)	

and	(5);	14	C.F.R.	§	61.113(a);	14	C.F.R.	§	61.315(a);	14	C.F.R.	§	91.7(a);	

14C.F.R.	§	91.119(c);	14	C.F.R.	§	91.121;	14	C.F.R.	§	91.151(a)(l);	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)	to	operate	unmanned	aerial	systems	for	

newsgathering,	commercial	production,	promotional	video,	and	

special	events	such	as	sporting	events,	wedding	ceremonies	and	

receptions.

VIII.	CONCLUSION
As	demonstrated	above,	the	UAS	operations	Dorosh	Documentaries,	

LLC has	proposed	in	this	petition	for	exemption	will	garner	significant	

public	benefits	while	presenting	minimal	safety	risks.	 Dorosh	

Documentaries,	LLC petition	satisfies	the	criteria	of	Section	333	of	the	

FMRA	and	is	substantially	similar	to	previous	petitions	the	FAA	has	

granted,	meriting	a	summary	grant	of	exemption.		Dorosh	

Documentaries,	LLC respectfully	requests	that	the	FAA	grant	this	

petition	to	enhance	Dorosh	Documentaries,	LLC ability	to	provide	

content	to	its viewership.

Please	do	not	hesitate	to	contact	Nazari	Dorosh,	Dorosh	

Documentaries,	LLC, CEO	at	doroshdocumentaries@gmail.com with	

any	questions	about	this	filing.

Sincerely,

Nazari	Dorosh

Dorosh	Documentaries,	LLC

7 id.§	11.81(f).