December 29, 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

AERIREEL, LLC’S PETITION FOR EXEMPTION

TO OPERATE UNMANNED AIRCRAFT SYSTEMS PURSUANT

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Proposed Use: Closed-Set Filming in the Motion Picture and 

Television Industries and

Aerial Data Collection

Proposed Aircraft: DJI Inspire 1, DJI Inspire 1 PRO, DJI Inspire 1 

RAW, DJI Phantom 2, DJI Phantom 3 Standard, 

DJI Phantom 3 Professional, DJI Matrice 100, 

DJI S900, and DJI S1000

Petitioner’s Contact Information: AeriReel, LLC

83 Geneva Drive #622168

Oviedo, FL 32765-9993

Attn: William Ferrara

Phone: (213) 700-2702

Email: andrewferrara@live.com
Petition of AeriReel, LLC| Page 2 of 12

I. Introduction

Dear Sir or Madam:

Pursuant to Section 333(a) through (c) (“Section 333”) of the FAA Modernization and Reform 

Act of 2012 ("Reform Act")1 and the Federal Aviation Administrations’ (“FAA”) general exemption 

authority under 49 U.S.C. §44701(f), AeriReel, LLC (“Petitioner”) petitions for exemption from 14 

Code of Federal Regulations (“CFR”) parts and/or sections: Part 21, Subpart H; Part 27, 45.23(b), 

45.27(a), 61.113(a) & (b), 61.133(a), 91.7(a), 91.9 (b)(2), 91.9(c), 91.103(b)(1), 91.109(a), 91.119 (c), 

91.121, 91.151, 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b). The proposed 

exemptions, if granted, would allow Petitioner to operate small unmanned aircraft systems ("UAS") 

weighing 55 pounds or less for the purposes of closed-set filming of motion pictures, television 

programs, and commercials as well as aerial data collection2 for the purposes mapping, 

photogrammetry, surveying, inspection, photography, videography, real-estate listings, motorsport 

activities, weather observation, and/or insurance underwriting. The proposed UAS shall include the 

following systems: DJI Inspire 1, DJI Inspire 1 PRO, DJI Inspire 1 RAW, DJI Phantom 2, DJI 

Phantom 3 Standard, DJI Phantom 3 Professional, DJI Matrice 100, DJI S900, and DJI S1000.

Based on the small size of Petitioner’s UAS, the qualifications and experience of Petitioner’s 

UAS operators, and controlled access environment within which Petitioner will operate, the 

requested exemptions fall squarely within the zone of safety envisioned by Congress and set forth in 

Section 333. Additionally, the enhanced safety achieved by replacing significantly larger manned 

aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew and 

operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good 

cause to find that the UAS operations enabled by this petition are in the public interest. Moreover, 

the requested exemptions are similar in all material aspects to the requests for which exemptions 

have been previously granted, e.g., Exemption Nos. 11289, 11062, 11109, 11112, and 11213. Thus, 

the requested exemptions should be granted.

II. Identity of Petitioner

AeriReel, LLC

83 Geneva Drive #622168

Oviedo, FL 32765-9993

Attn: William Ferrara

Phone: (213) 700-2702

Email: andrewferrara@live.com

 1 Pub. L. 112-95 (2012), 126 Stat. 11 (2012).

2

 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include 

imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical 

measurement (particulate measurement, etc.), or any other gathering of data by an instrument(s) aboard the UA. 
Petition of AeriReel, LLC| Page 3 of 12

III. Statutory Authority for Exemptions

The Administrator of the Federal Aviation Administration possesses both general and specific 

authority to grant the requested exemption.

First, the FAA Administrator may exempt an operator from FAA safety regulations and 

minimum standards when the Administrator concludes that the exemption is in the public interest. 

See 49 U.S.C. §§ 106(f), 40113, 44701(±) (permitting exemptions from §§ 44701(a), (b) and §§ 44702-

44716, et seq.). A party requesting an exemption must explain why the exemption: (1) would benefit

the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of 

safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

Second, Section 333 of the Reform Act specifically authorizes the FAA Administrator to grant 

exemptions for operation of UAS. Indeed, the Reform Act directs the Administrator to (1) undertake 

formal rulemaking to speed up the integration of UAS into the national airspace (“NAS”) but in the 

meanwhile, (2) to permit unmanned aircraft systems to operate in the NAS if doing is in the public 

interest, does not pose a threat to national security, and does not create a hazard to users of the 

NAS, taking into consideration the following:

• The UAS's size, weight, speed, and operational capability;

• How close the UAS would operate to airports and populated areas;

• That the operator would keep the UAS in his direct, visual line of sight.

Thus, the FAA has the full authority to grant the requested exemptions.

IV. Specific Regulations for Which an Exemption is Sought

Petitioner requests exemptions from the following regulations contained in 14 C.F.R.:

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met with this petition, and 

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-0352 at 

13-14, 22. If the FAA determines that there are some characteristics of the UAS that fail to meet the 

requirements of the Reform Act, an exemption is requested.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the UASs would otherwise require certification under Part 

27, Petitioner seeks an exemption from Part 27’s airworthiness standards for the same reasons 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.
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C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements

14 C.F.R. § 45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted,” “light-sport, “experimental,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. 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.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft “have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See

Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.

D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Section 61.113 prescribes that “no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an aircraft,” (see Section 

61.113(a)), and that “a private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire,” (see Section 61.113(b)).

E. 14 CFR 61.133 - Commercial pilot privileges and limitations.

Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, 

including a provision impliedly limiting to persons holding a commercial pilot certificate the ability 

to act as pilot in command of an aircraft “[f]or compensation or hire.”

F. 14 C.F.R. § 91.103: Preflight Action

Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, before 

beginning a flight, become familiar with all available information concerning that flight, to include, 

“For any flight, runway lengths at airports of intended use, and the following takeoff and landing 
Petition of AeriReel, LLC| Page 5 of 12

distance information:...(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the takeoff and landing distance 

data contained therein”

G. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes: “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.”

H. 14 C.F.R. § 91.121: Altimeter Settings

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or 

an appropriate altimeter setting available before departure.”

I. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after 

that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes.

J. 14 CFR 91.203 - Civil aircraft: Certifications required

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless it 

has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the second copy 

of the Aircraft Registration Application as provided for in October 1, § 47.31(c). Section 91.203 

prescribes, in subpart (b), that no person may operate a civil aircraft unless the airworthiness 

certificate 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.

K. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have 

the aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as 

prescribed in Part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that 

has undergone maintenance, preventative maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under §43.7 of the same chapter.
Petition of AeriReel, LLC| Page 6 of 12

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with Part 21 of this chapter.

Sections 91.417(a) and (b) prescribe, in pertinent part, that-

(a) Each registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section:

(1) Records of the maintenance, preventative maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft and 

its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revisions date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.
Petition of AeriReel, LLC| Page 7 of 12

V. Petitioner’s Proposed Operations to Satisfy Section 333

A. Unmanned Aircraft Systems

The Unmanned Aircraft Systems (UAS) to be operated under this request are less than 55 lbs. 

at Maximum Takeoff Weight (MTOW), will be operated at a speed of no more than 87 knots (See, 

e.g., Exemption No. 11289 (Bird’s Eye Solutions), p. 3, condition (3), carry neither a pilot nor 

passenger, carry no explosive materials or flammable liquids, and operate exclusively within a 

controlled access area. Petitioner’s UAS use radio frequencies within the electromagnetic spectrum 

for operation and control that complies with Federal Communications Commission (“FCC”) 

requirements, and Petitioner has integrated safety features into the UAS, as described in the Motion 

Picture and Television Operations Manual (“MPTOM”). Petitioner is tendering the MPTOM under 

separate cover as a confidential and proprietary document as defined in 14 C.F.R. § 11.35(b). The 

entire MPTOM contains confidential commercial and proprietary information that the Petitioner has 

not and shall not share. The operating conditions and procedures contained in the MPTOM are not 

available to the public and are protected from release under the Freedom of Information Act, 5 

U.S.C. § 552 et seq., and any other requirements established by the FAA pursuant to Section 333 of 

the FAA Reform Act.

Petitioner’s UAS are equipped with redundant safety mechanisms allowing them to operate 

safely after experiencing certain in-flight failures. If a lost-link event occurs, including the loss of 

ground communications and/or the loss of a GPS signal, Petitioner’s UAS have the ability to perform 

a pre-coordinated, predictable, automated flight maneuver and return to a predetermined location 

within a designated security perimeter for landing. The UAS further have the ability to abort a flight 

in the event of unpredicted obstacles or emergencies. All flights will be terminated so there is at least 

five minutes of remaining power to operate the UAS safely. Thus, good cause exists for granting 

Petitioner’s requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for flight in 

VFR conditions).

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. 

Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, 

Subpart C. Markings will be as large as practicable.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), 

Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter onboard 

the UAS. Instead, altitude information will be provided to the UAS PIC via a digitally encoded 

telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. The 

altitude information will be generated by equipment installed onboard the UAS, using GPS 

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by 

the UAS PIC. Thus, good cause exists for granting the requested relief from 14 C.F.R. § 91.121.

Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized by the Petitioner, an exemption from 14 C.F.R. Part 21, Subpart H (Airworthiness 
Petition of AeriReel, LLC| Page 8 of 12

Certificates), subject to certain conditions and limitations, is warranted (if necessary) and meets the 

requirements for an equivalent level of safety under 14 C.F.R. Part 11 and Section 333. The UAS 

operated without an airworthiness certificate in the controlled access environment and under the 

conditions and limitations proposed by Petitioner will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued 

under 14 C.F.R. Part 21, Subpart H, and not subject to the proposed limitations and conditions.

Petitioner will strictly comply with safety and maintenance procedures included in all 

applicable UAS manufacturer’s instructions and operating manuals. To the extent such information 

is not included in the guidelines developed by the manufacturers, Petitioners will develop and 

document maintenance, overhaul, replacement, and inspection requirements, procedures to 

document and maintain maintenance records with regard to Petitioner’s UAS, and UAS technician 

qualification criteria. Petitioner’s operations manuals will include maintenance requirements for 

Petitioner’s UAS, including “on-condition” maintenance and modifications. In light of these 

mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b) are warranted.

B. UAS Pilot in Command

Petitioner’s UAS pilot in command (PIC) must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate, and valid driver’s license to satisfy the medical 

requirement. According to the FAA, “the FAA considers the overriding safety factor for the limited 

operations proposed by the petitioner to be the airmanship skills acquired through UAS-specific 

flight cycles, flight time, and specific make and model experience, culminating in verification 

through testing.” See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 18. With 

those factors in mind, Petitioner’s UAS PIC shall be required to meet several conditions and 

limitations as outlined in the MPTOM, including the following:

• The UAS PIC will have accumulated and logged a minimum of 200 flight cycles and 25 hours 

of total time as a UAS pilot and at least 10 hours logged as a UAS pilot with a similar UAS 

type (single blade, multirotor, or fixed-wing).

• The UAS PIC will have accumulated and logged a minimum of five hours of flight time with 

the specific make and model of the UAS to be utilized for operations under the exemption 

and three takeoffs and landings in the preceding 90 days.

• The UAS PIC will have successfully completed the qualification process as specified in the 

operations manuals, to include a knowledge and skill test.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s 

understanding that Petitioner’s UAS will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessary. 

To the extent such an exemption is deemed necessary, Petitioner asserts that it should be granted in 

light of the safety procedures proposed herein. In accordance with the pertinent part of 14 C.F.R. § 

91.7(b), the operator in command of Petitioner’s UAS shall be responsible for determining whether 
Petition of AeriReel, LLC| Page 9 of 12

the aircraft is in a safe condition for flight. Petitioner’s manuals for maintenance and operations 

shall include safety checklists to be used by the operator in command prior to each flight.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight 

manual, marking, and placard requirements and § 91.203(a) and (b), (Civil aircraft: certifications 

required), it is Petitioner’s understanding that relief from these regulations is no longer necessary in 

light of the FAA Memorandum “Interpretation regarding whether certain required documents may 

be kept at an unmanned aircraft’s control station,” dated August 8, 2014. To the extent the FAA 

deems an exemption from this section necessary for Petitioner’s proposed operations, such exemption 

should be granted in light of the mitigating fact that Petitioner will maintain the documents 

required under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station during flights. 

Additionally, 100% of Petitioner’s operations will utilize a visual observer (“VO”). The VO may be 

used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 

and the PIC will be able to communicate verbally at all times during operational flights.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply 

with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the 

PIC will take all actions including reviewing weather, flight battery requirements, aircraft 

performance data, and landing and takeoff distances before initiation of a flight. The PIC will also 

account for all relevant site-specific conditions in their preflight procedures.

C. Operating Parameters of Petitioner’s UAS

Petitioner’s UAS operations will be conducted within a sterile environment of closed-set 

filming. In this controlled environment, Petitioner’s operations will remain within VLOS of the PIC 

and VO, below 400 feet AGL, and at speeds below 87 knots. See Exemption No. 11289, p. 3, C. 3, 4) 

Only participating persons will be permitted within the operating area. Consistent with the relief 

typically provided to manned operations under FAA Order 8900.1, Volume 3, Chapter 8, Section 1, 

Petitioner requests relief from 14 C.F.R. § 91.119(c) with respect to those participating persons, 

vehicles, and structures directly involved in the performance of the actual filming. Regarding 

distance from participating persons, the operations manuals set forth safety factors for authorized 

and consenting production personnel. Because those procedures are specific to participating persons, 

no further FSDO or aviation safety inspector approval is necessary for reductions to the distances 

specified in Petitioner’s manuals.

Regarding the distance from nonparticipating persons, Petitioner will ensure that no persons 

are allowed within 500 feet of the operating area except those consenting to be involved and 

necessary for the filming production, with the possibility of reducing this distance to no less than 200 

feet if it would not adversely affect safety and the Administrator has approved it. This is consistent 

with FAA Order 8900.1, V3, C8, S1.

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center of 

a non-towered airport unless a letter of agreement with that airport’s management is obtained and 

the operation is conducted in accordance with a Notice to Airmen (“NOTAM”). Additionally, 

Petitioner will not operate in Class B, C, or D airspace without prior written approval from the 
Petition of AeriReel, LLC| Page 10 of 12

respective tower. Nor will Petitioner operate the UAS less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

Petitioner’s UAS will remain clear and yield the right of way to all manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders).

Although Petitioner seeks to comply with the waiver process as described in FAA Order 

8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and 

Television Filming), the current section of Order 8900.1 has specific processes that preclude a 

jurisdictional FAA FSDO from issuing the required Certificate of Waiver, because the section did not 

originally provide for UAS operations. Thus, Petitioner seeks exemption from the applicable 

regulations normally waived during that process. Petitioner proposes that the FAA include the 

required notifications and coordination with jurisdictional FSDOs through the conditions and 

limitations accompanying the requested exemption, and that the exemption sought herein will take 

the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 8900.1. Under 

this rubric, Petitioner will notify every FSDO with jurisdiction over the area that Petitioner plans to 

operate, just as with manned filming operations, and those FSDOs will have the ability to coordinate 

further conditions and limitations with the UAS Integration Office to address any local concerns.

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or 

Authorization (“COA”) prior to conducting any operations under this grant of exemption. In fulfilling 

its requirements under the COA, Petitioner will be required to request a NOTAM not more than 72 

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

D. The Requested Exemption Promotes the Public Interest

The enhanced safety achieved by replacing significantly larger manned aircraft carrying crew 

and flammable fuel with small UAS carrying no passengers or crew and operated under the specific 

guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS 

operations enabled by the instant Petition are in the public interest. Moreover, as the FAA has 

already recognized, “UAS provide an additional tool for the filmmaking industry, Agriculture and 

Conservation adding a greater degree of flexibility, which supplements the current capabilities 

offered by manned aircraft.” See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 

22.

VI. Privacy

All flights will be conducted over private or controlled access areas with the permission from 

the property owner/controller or authorized representative.
Petition of AeriReel, LLC| Page 11 of 12

VII. Summary for the Federal Register

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:

Petitioner seeks an exemption from the following rules to allow for UAS operations for the 

purposes of closed-set filming of motion pictures, television programs, and commercials as well as

aerial data collection for the purposes mapping, photogrammetry, surveying, inspection, 

photography, videography, and/or insurance underwriting: 14 C.F.R. Part 21, Subpart H; 14 C.F.R 

Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 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; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 

91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 

91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

VIII. Conclusion

For the reasons explained above, the regulatory exemptions requested should be granted, and 

Petitioner should be permitted to conduct small UAS operations for the purposes of closed-set filming 

of motion pictures, television programs, and commercials as well as aerial data collection for the 

purposes mapping, photogrammetry, surveying, inspection, photography, videography, and/or 

insurance underwriting using the DJI Inspire 1, DJI Inspire 1 PRO, DJI Inspire 1 RAW, DJI 

Phantom 2, DJI Phantom 3 Standard, DJI Phantom 3 Professional, DJI Matrice 100, DJI S900, and 

DJI S1000.

Petitioner has satisfied the requirements of Section 333 of the Reform Act to permit operation 

the UAS proposed here. This petition warrants review by the FAA under the “summary grant” 

process for immediate approval as this petition would not set a precedent, and any delay in acting on 

this petition would be detrimental to the Petitioner.

If you have any questions or require any additional information, please do not hesitate to 

contact the undersigned representative of the Petitioner.

Respectfully submitted,

AERIREEL, LLC

83 Geneva Drive #622168

Oviedo, FL 32765-9993

/s/ William Ferrara

William Ferrara

President
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Attachments

(The following attached items will be submitted under separate cover as they contain proprietary

and commercial information exempt from disclosure under the Freedom of Information Act,

5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

Motion Picture and Television Operations Manual