US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA

Reform Act and Part 11 of the Federal Aviation

October 18, 2015

Keith Dezmin

111 Vakerich Place

South Plainfield, NJ 07080

(908) 246-0481

kdezmin@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 

14 CFR91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 

14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 

(a)(1) and (2); 14 CFR91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act")

and 14 CFR Part 11, Dezmin Media, operator of Unmanned Aircraft Systems (UAS), hereby applies for 

an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of 

designated UAS, provided such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333.

The pilot, Keith Dezmin, has been flying since he was 16 years old and is well acquainted with FAA rules 

and regulations. He looks to couple his years of flying into a service that provides clients with high 

quality digital content for use in their commercial and personal multimedia endeavors.

Thank you in advance for your consideration.
Aircraft

Dezmin Media seeks an exemption to operate the following UAS devices-all of which have been 

approved in previous 333 petitions: 

DJI Phantom 3 Professional http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

DJI Phantom 2

DJI Phantom 3 Advanced – http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf

DJI Inspire 1 – http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

DJI Phantom 2

DJI Phantom 2 Vision+,

DJI Inspire 1

DJI S1000+ 

DJI S900

Freefly Cinestar 8

Tarot 680 Sport UAS

3D Robotics IRIS+ https://3drobotics.com/wp-content/uploads/2014/04/IRIS-Operation-Manual-v6.pdf

3D Robotics Solo https://3drobotics.com/kb/solo-user-manual/

3D Robotics X8+ http://3drobotics.com/wp-content/uploads/2014/11/X8+-Operation-Manual-vA.pdf

3D Robotics X8-M when weighing less than 55 pounds including payload

https://3drobotics.com/wp-content/uploads/2014/10/X8M-Operation-Manual-v1.pdf

Gryphon Dynamics X8

Foxtech Kraken 130

Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

THE UNMANNED AIRCRAFT mentioned above would all meet the below criteria for flights.

• All have weights less than 8 pounds and would weight no more than 55 pounds including payload.

• An on-board flight computer with GPS navigation and location ability that receives signals for flight 

controls from a ground-based transmitter/controller
• An on-board camera capable of capturing imagery in the form of full color, high definition still photos 

and video

• An on-board telemetry system that delivers flight data from the on-board flight computer to the onboard radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight 

and direction back to its launch site

• A 2.4GHz or 5.8GHz on-board radio transmitter that transmits live video from the on-board camera plus 

all the flight data from the telemetry system described above; THE GROUND STATION -BASED PART 

OF THE SYSTEM

• A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who 

controls the UA while in the air

• A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight

• A radio receiver receiving live video and flight data from the on-board camera and computer projects it 

all together onto a screen for the PIC to view during flight

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while 

in flight.

All aircraft will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking.

The sUAS will be maintained in accordance with the manufacturers instruction manual and only 

manufacturer's authorized replacement parts will be used.

All sUAS Pilots in Command (“PICs”) acting as an employee or agent of Dezmin Media for its sUAS 

operations will have at least a private pilot certificate from the FAA and a valid driver’s license (or 

appropriate medical certificate) with additional experience in unmanned aircraft operations.

Commercial operation of an UAS, as described herein, which are equipped with camera(s)

And sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, golf courses, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and newsgathering.

1. Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

2. Aerial video/photography for agriculture activities.

As described fully below, the requested exemption would permit the operation of designated

UAS as set forth in this document under controlled conditions in the NAS that would be a)

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of

Transportation's (the FAA Administrator's) responsibilities to " .... establish requirements
for the safe operation of such aircraft systems in the national airspace system."

Benefit Public

Approval of these 333 exemptions in general would allow commercial operations of small UAS to 

provide numerous services that would benefit from aerial imaging and data collection while greatly 

enhancing safety by reducing the overall risk associated with traditional aircraft. Traditional aerial 

imaging requires large aircraft, such as helicopters, with flammable fuel to fly in close proximity of 

populated areas and people and often in sub-optimal states of their height-velocity curves. With the use of 

small UAS of 55 lbs. or less that are battery operated and flying below 400 feet AGL, the risk of injury of 

people on the ground or the crew is greatly minimized in comparison. Conducting aerial acquisitions with 

UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial video and still photography flight operations.

Aside from the lack of flight crew members located onboard the aircraft, the THE AIRCRAFT UAS 

(weighing no more than 10 pounds and with no fuel on board), has less physical potential for collateral 

damage to life and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

Privacy

All flights will occur over private or controlled-access property with the property owner’s or controlling 

authority’s prior consent and knowledge. Aerial photography and video capture will be of people who 

have provided their written consent to being photographed or have been authorized to be in the area 

where flight operations are taking place. Establishing and maintaining tight controls over access to the 

flight operations area will minimize privacy issues. Similar to the manned aerial acquisition flight

operations that have been conducted for decades, Dezmin Media’s proposed operation of the sUAS will 

not implicate any privacy issues. Specifically, sUAS will be operated under detailed operational protocols 

designed to ensure client or property owner involvement as well as local law enforcement notification.

Safety

The operation limitations proposed for an equivalent or higher level of safety because

operations will further enhance the safety of the persons and/or property using conventional

aircraft. These limitations and conditions to which the applicant agrees to adhere to when

conducting commercial operations under the FAA issued exemption as set forth in the Flight

Operations Manual (FOM) include:

1. The UAS will weigh significantly less than 55 lbs. The UAS being used all have weights of less than 

10 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of

no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual

Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in

operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power

reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL)

and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual
Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a

minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day's flights consisting of all the days'

production activities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a Smile radius of the geographic

center/ Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/ Airport.

13. The operator will file FAA Form 77111, or its equivalent, as modified in light of the

requested exemption, with the appropriate local Flight Standards District Office (FSDO) no

more than 72 hours but no less than 48 hours from planned operation.

14. The operator will obtain verbal/written consent of all persons involved with the planned

operation and ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety

determination, as U.S. Department of Transportation required under the FOM. With the

advanced permission of the FSDO, operations at closer

range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to date

information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. Written and/or verbal permission and permits will be obtained from territorial, state, county

or city jurisdictions, including law enforcement, fire or other appropriate governmental

agencies as appropriate to flight operations.

18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS

will have the capability to return to a predetermined location within a designated location and

land autonomously.

19. The UAS will have the capability to abort a flight in case of emergencies with an

automated "Return Home and Land" function.

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles,

weather, or emergencies such as low battery.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and

operating handbook. An equivalent level of safety will be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of

time. If mechanical issues arise the small UAS can land immediately and will be operating from no higher

than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating

flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an

airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual

(AOM). As provided in the FOM, the operator will ensure that the small UAS is in working order prior to
initiating flight and perform required maintenance needed.

Exemptions wanting relief from:

CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA 

to 

exempt aircraft from the requirement capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed-wing or multi-rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a Pilot nor Observers, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area 

as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the Operator, pursuant to safety requirements, and under the 

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

of operation as is now done with conventional tools. The FAA will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

Videography and Photography production, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, 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 external load. 

14 CFR §45.23 (B): Marking of the Aircraft 

The regulation requires: 

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. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be D

placed. Given the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will 

be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the Operator (PIC) and Observers and others working with the sUAV will see the 

identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations -Pilot in Command (PIC) 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not 

carry a Pilot or Observers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a 
commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the 

Operator (PIC) and Observers, the UAS is remotely controlled with no living thing on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth 

in the Manual. The level of safety provided by the requirements included in the Manual exceeds that 

provided by single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety 

achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Aircraft Airworthiness 

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 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists and a preflight 

inspection, all maintenance and alterations will be properly documented in the aircraft records prior to 

each flight, an equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Multi-rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Multi-rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700 

14 CFR §91.103: Preflight Action 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved multi-rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided in the Manual. The PIC will take 

all actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight.

14 CFR §91.109: Flight Instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos. 

5778K & 9862A. The equivalent level of safety provided by the fact that aircraft. 

14 CFR §91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a UAS that is a fixed-wing or multi-rotorcraft requests authority to operate 
at altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which filming 

inspections is planned, an exemption may be needed to allow such operations. As set forth herein, 

except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 ft. 

AGL. It will however be operated in restricted area with security perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations as set forth in the Manual. 

Compared to flight operations with aircraft or multi-rotorcraft weighing far more than the maximum 55 

lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operating at or below 500 ft. AGL in this 

industry. In addition, the low-altitude operations of the UAS will ensure separation between these small 

UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires 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.” As the small UAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

14 CFR

This regulation requires 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.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the 

GPS altitude indicator before flight. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “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.” 

The battery powering the UAS provides approximately 40 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners 

or official representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given 

the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly 

reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 
25% of battery power whichever happens first. This restriction would be more than adequate return the 

UAS to its planned landing zone from anywhere in its limited operating area. 

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent 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... 

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

paragraph (b) 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. 

The UAS fully loaded weighs no more than 10 lbs. and is operated without an onboard Pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the Pilot flying the UAS will have immediate access to them, to the extent they are applicable to 

the UAS. 

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph © of this section, have discrepancies repaired as prescribed in Part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to 

the flight manual and operating handbook as referenced in the Manufactures Manual. An equivalent 

level of safety will be achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the 

UAS can land immediately and will be operating from no higher than 400 ft. AGL. As provided in the 

Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. 

Publication in the Federal Register

The following summary is provided for publication in the Federal Register, should it be determined that 

publication is needed. Dezmin Media seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR 21 subpart H; 14 

CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 

91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 

(a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b). This exemption 

request will permit Dezmin Media to operate its UAS devices commercially for the purpose of aerial 

filming and photographing to include: commercial and residential real estate, infrastructure inspections, 

construction, architecture, scientific research, environmental assessment, land surveying and mapping. 

Dezmin Media will provide a service that is beneficial to industries and organizations that are already 

using, and/or seeking to use, sUAS’s for these purposes with a legal and safe option. This will benefit the 

public with the controlled operation of sUASs and increase their integration into the NAS. The requested 

exemption should be granted because the proposed operation of the small UAS (sUAS) weighing no more 

than 10 lbs., inclusive of battery and payload, conducted in the strict conditions outlined below, will 

provide an equivalent or better level of safety, as Congress intended, while still allowing commercial 
operations. The lightweight aircraft covered by the exemption is 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 is small, and 

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

population environment.

Enclosures: 

 DJI S1000 User Manual

 Phantom 2 User Manual

 Cinestar 8 Manual

 GD-x8 User Manual

 K130 v2 User Manual