Tuesday, April 21, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

by/for Cedarmeade Studios, LLC

429 Beechcroft Road 

Winchester, VA 22601 

 

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam, 

This petition is being submitted with no legal counsel or consulting services.

This document constitutes an exemption Request under Section 333 of the 

FAA Modernization and Reform Act of 2012 for Aviation Unmanned to 

perform Aerial Photography by/for Cedarmeade Studios, LLC. The main use 

of this UAS would be obtaining aerial video and still images for clients 

(categories listed below) and obtaining aerial still images for sale to the 

general public through online galleries. The UAS systems that I plan to use is 

a DJI Inspire 1 and will be referenced in this document and also in the 

attached user manual. 

The requested exemption would permit Cedarmeade Studios, LLC to pursue 

its commercial interests in providing services to clients using a small 

advanced UAS in the following areas: 

• Real Estate/Architecture 

• Marketing

• Surveying/Mapping 

• Industrial Surveying

• Sporting Events 

• Special Events/Festivals 

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Regulations from which exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.401 – 91.417

Unmanned Aircraft System

UAS are often seen as superior to helicopters as an aerial video gathering 

platform due to the smaller devices, more affordable equipment and 

personnel cost, reduced noise and as such, a much smaller environmental 

impact which promotes public safety.

Cedarmeade Studios, LLC is petitioning for an exemption to operate a DJI 

Inspire 1 with a built-in stabilized HD camera and the following GPS safety 

features: 

• Restricts the height above ground level (AGL) to a specified usergenerated height. 

• Restricts the radius of flight from the ground station to a user-generated 

radius. 

• Restricts operations within designated Class B, C and D airspace 

including a no-fly zone feature.

The DJI Inspire 1 also has a failsafe function that is triggered in the event 

communications are lost between the UAS and the main controller 

transmitter. In the unlikely event this occurs, the UAS will return to its point 

of takeoff and land safety. If communications are restored, the PIC can 

regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards (AC 

91-57) as set below:

1. The petitioner will only operate its UAS in line-of-sight of a pilot and/or 

observer and will operate at sites that are ‘sufficient distance’ from 

populated areas within the sterile area described in the FOPM. Such 

operations will ensure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” The orientation of flights will 

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be such that the pilot in command (PIC) always has a visual on the rear 

mounted LED flight Indicator. Additional safety features on the DJI 

Inspire 1 include, return to home, low battery energy level, enhanced 

failsafe along with operating in the less populated 5.8 GHZ frequency 

range. 

2. When flying the UAS within three (3) miles of an airport, airport 

operators will be notified and the operator will give the right-of-way to 

avoid flying in the proximity of full-scale aircraft. 

3. Pre-flight inspection would be checking battery condition/level in both 

the transmitter and UAS, a visual/operational check of the propellers, a 

visual/operational check of the aircraft, a visual/operational check of the 

motors, a full compass and IMU calibration, a visual/operational check of 

the transmitting radio control unit, a visual/operational check of the 

camera and gimbal unit and a visual/operational check of the vision 

positioning system. A check for power-lines, antennas and other 

overhead objects would also be performed. Wind conditions would be 

monitored and be a factor for flying.

4. The radio frequency of the DJI Inspire 1 is in 5.725~5.825 GHz range 

the FC350 camera 2.400~2.483 GHz. Maximum take-off weight 

approximately 3000g. Max Ascent/decent speed 5 m/s. Maximum flight 

Velocity 22 m/s. The UAS operated by the petitioner weighs less than 

15 pounds, including all payload (i.e. camera, lens, and stabilized 

gimbal).

5. The PIC will be only myself and I have a minimum of 55 hours flying 

time with DJI equipment, approximately 10 of those hours with this 

specific model (DJI Inspire 1). I’m a freelance video producer and 

photographer with over 10 years of photography/videography 

experience. Testing, updating and programming the DJI Inspire 1 

firmware would be done on a monthly schedule. 

6. Flights will be terminated when battery energy levels reach 25%, 

allowing sufficient reserve flight time to safely land the UAS.

7. The UAS will be programmed so it will not be operated at an altitude 

that exceeds 400 feet AGL, and not more than 150 feet above a 

significantly elevated geographic position from which videography/

photography is planned. 

8. I’m in good medical health and sound mental health with no arrests or 

felonies. 

9. The intended use of this DJI Inspire 1 is to supplement my existing 

photography business with aerial photographs and video. The aerial 

vantage point/perspective would allow my studio to provide a service to 

local advertising clients that is different/unique and competitive. 

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10. All photo/video flights would have the date, time, GPS coordinates along 

with the camera metadata recorded in an in-app flight log on the mobile 

device serving as the in-flight monitor. This flight log records flight path, 

altitude, flight time, number of images shot, amount of video shot, date, 

time, and total flight distance. Each individual flight has the capability of 

playing back (in-app) in real time and is synced across devices via DJI’s 

in-app User Center. 

11. Given the small size of the UAS and the restricted sterile environment 

within which it will operate, Cedarmeade Studios, LLC’s operations will

adhere to the Reform Act’s safety requirements. 

12. The DJI Inspire 1 will never be flown in the flight path of manned 

aircraft. with the first condition listed, always keeping a visual line of 

sight, being of utmost importance to providing a significant level of 

public safety.

I respectfully request exemption under Section 333 to enable Cedarmeade 

Studios, LLC to operate efficient, limited, low-risk commercial UAS 

operations for the activities stated respecting at all times the space and 

privacy of citizens and property while keeping airspace safe. 

Respectfully,

Cedarmeade Studios, LLC

429 Beechcroft Road 

Winchester, VA 22601 

Home/Cell: (540)533-3775 

www.cedarmeadestudios.com

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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Cedarmeade Studios, LLC requests an exemption from the following 

regulations as well as any additional regulations that may technically apply 

to the operation of the UAS System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop airworthiness 

standards for Unmanned Aerial Systems, we request an experimental 

certificate be issued for the DJI Inspire 1 under either, or both, of the 

following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the 

following purposes:

(a) Research and development. Testing new aircraft design concepts, 

new aircraft equipment, new aircraft installations, new aircraft operating 

techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness regulations 

including flights to show compliance for issuance of type and supplemental 

type certificates, flights to substantiate major design changes, and flights to 

show compliance with the function and reliability requirements of the 

regulations.

Since the experimental certificate can be used for commercial purposes such 

as market surveys, sales demonstrations, and customer crew training, we 

would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry 

fuel, and will only fly under strict operational requirements. Combined with 

the UA's light weight, being constructed primarily of carbon fiber and plastic, 

we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, 

then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks 

These regulations provide that each aircraft must display "N" and the 

aircraft's registration number in letters at least 3 inches high. Additionally, 

the aircraft must display the word "EXPERIMENTAL" in letters at least 2 

inches high near the entrance to the cabin, cockpit, or pilot station. The UAS 

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does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in a placard on the top of the aircraft where the PIC, VO 

and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground 

station. Finally, we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in 

letters adhering to the specifications of at least 2 inches and less than 6 

inches. Since the aircraft will operate in close proximity (not more than 1/2 

NM) to the ground station, the banner should be visible to anyone that 

observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an 

airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard 

requirements. 

This regulation provides that no person may operate an aircraft unless a 

current, approved flight manual is in the aircraft. We assume that the intent 

of this requirement is to ensure that flight manual information is available to 

the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, 

the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that the manual be kept in a digital format on a mobile 

device at the ground station. A hard copy will also be kept inside the 

equipment carrying case (in the event the digital version is unavailable) and 

available to the crew at the ground station anytime the aircraft is in, or 

preparing for, flight. 

91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot 

be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Since the typical mission of the UAS would be photography or survey of 

persons, vessels, vehicles or structures it would, at times, be necessary to 

operate closer than 500 feet to the items listed. Operations will only be flown 

over property or persons where permission has been obtained and careful 

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pre-planning has been performed. The aircraft will be operated at a low 

altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. Therefore we maintain that 

due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by 

reference to an altimeter setting available within 100 NM of the aircraft. The 

UAS will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground 

Level altimeter measurement above the takeoff point is transmitted via radio 

from the UAS on-board computer to the display screen held by the PIC, 

providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane 

under day-VFR conditions unless there is enough fuel to fly to the first point 

of intended landing and to fly after that for at least 30 minutes and nightVFR conditions an additional 45 minutes. We feel the intention of this 

paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UAS is battery operated and the maximum duration of flight 

from a single battery charge is approximately 15 minutes with an additional 

25% reserve. Since the aircraft will never fly more than 1/2 NM from the 

point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. The PIC has a 

visual reference to the remaining battery energy level and an estimated 

“return to home” energy requirement. We request an exemption to the word 

"fuel" and ask for an equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the 

registration number assigned to the aircraft and a registration certificate 

must be aboard the aircraft. Additionally, subparagraph (b) provides that the 

airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew." At a maximum gross weight of 5.3 

pounds, the UAS is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located 

with the crew at the ground control station and available for inspection upon 

request. In order to identify the aircraft, we propose that the information 

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found on airworthiness and registration certificates be permanently affixed to 

the aircraft containing such information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E 91.401- 91.417 - Maintenance, Preventive 

Maintenance, Alterations

The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with 

part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform 

maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. Maintenance performed by the 

PIC is limited to repairing small cracks, replacing a propeller, checking 

electrical connections and updating software and firmware for the on-board 

computer. All other maintenance will be performed by the manufacturer or a 

manufacturer-designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent 

level of safety. 

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