U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140 

Washington, DC 20590 

January 20, 2016

Petitioner:

Skypoint Films, LLC

Wes Hoffman, Managing Director

5103 S. Sheridan #523 

Tulsa, OK 74145

Tel.: 918.995.0900

Fax: 800.591.4590

Email: wes@skypointfilms.com

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 11.81, Skypoint Films, LLC., hereby applies for 

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

commercial operation of its small, unmanned aircraft for photography, 

videography, advertising, inspection, and analyses. All operations will be 

conducted within and under the conditions and limitations outlined previously by 

the FAA as required by Section 333 and conducted in compliance with the 

attached operator’s manuals. 

1. Sections from which exemptions are sought: Application is hereby made for 

exemption from: 

A. 14 CFR Part 21, subpart H 

B. 14 CFR Part 61.113(a) and (b) 

C. 14 CFT Part 91: 

 I. 91.103(b)(2) 

 II. 91.105

 III. 91.109

 IV. 91.119 

 V. 91.121 

 VI. 91.151 

 VII. 91.405 

 VIII. 91.407 

 IX. 91.409 

 X. 91.417 
2. Relief Sought:

A. Skypoint Films, LLC. wishes to operate small Unmanned Aircraft 

Systems (sUAS) for commercial purposes to include (but not be limited 

to) photography, videography, advertising, inspection, and analyses. 

B. This relief is sought because commercial use of sUAS is currently 

prohibited by law unless performed under an exemption.

C. This exemption will cover use of the following airframes, all of which 

will weigh less than 55 pounds including payload and energy sources: 

I. DJI Inspire 1 (see www.dji.com/product/inspire-1)

II. DJI Phantom 3 (see www.dji.com/product/phantom-3)

III. Other models to be added by future amendment to this 

exemption. 

3. Public Benefit:

A. Use of sUAS technology to obtain imagery, information and data 

currently obtained by use of manned flight or manual methods: 

I. Reduces statistical risk to human life due to manned aircraft 

accidents (e.g., infrastructure inspections) and due to other 

dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections).

II. Reduces the cost of obtaining such information, which benefits 

consumers and the economy. 

III. Reduces environmental impact by eliminating sources of 

hydrocarbon emissions from manned aircraft. 

B. Skypoint Films, LLC. will instruct and advise others interested in flying 

UASs to do so safely and legally in the NAS. 

4. Safety Not Adversely Affected:

A. Aircraft will be registered and marked in accordance with Section 

44711 and Part 47 and Part 45, Subpart C.

B. Aircraft will comply with maintenance and inspection requirements of 

the manufacturer and will require a test flight after such work. Records of 

all maintenance and repair work will be kept in a maintenance log for each 

aircraft.
C. All flight operations will be conducted by at least two individuals (PIC 

and observer) who will maintain verbal communication capability with 

each other at all times during the flight, and who will remain stationary on 

the ground during the flight operations: 

I. A Pilot In Command (PIC) who possess the following 

credentials:

1. An Airman Certificate issued under 14 CFR 61 (private 

pilot license) screened by the TSA.

2. A Third Class medical certificate issued under 14 CFR 

67.

3. A bi-annual flight review under 14 CFR 61.56.

4. Successful completion of a UAS knowledge test in a 

specified form.

5. At least 5 hours of flight experience and 3 takeoffs and 

landings in make and model being flown in the prior 90 

days. Such cycles and hours may be gained during flights 

under this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119. 

II. A Visual Observer as necessary.

D. All flight operations will be conducted in accordance with valid 

Certificates of Authorization. 

E. All flight operations will comply with the following: 

I. The manufacturers’ user manuals.

II. Skypoint Film’s Flight Operations and Procedures Manual 

(FOPM) and Aircraft Flight Manuals (AFM) which include lost 

communication and other emergency and safety procedures. 

III. Conducted in VMC conditions during daylight hours.

IV. sUAS will maintain VLOC at all times.

V. PIC and VO will maintain VLOS at all times. 

VI. Pre-flight inspections (including ground control station, if any) 

and safety risk assessments will be conducted prior to each flight.
VII. Flight altitudes will remain below 400 feet above ground 

level.

VIII. Flight ground speeds will not exceed 50 knots. 

IX. Not intrude into Class B, C or D airspace, or published 

approach, SID or STAR, or take place within 5 nautical miles of an 

airport.

X. Not be made near persons as required in 14 CFR 91.119 and not 

over persons on the ground without their prior permission. 

XI. Each flight will be logged in both the PIC’s logbook and the 

aircraft logbook.

XII. Any incidents will be reported within 24 hours of occurrence.

XIII. Skypoint Films, LLC. will maintain liability insurance of at 

least $1,000,000.

XIV. Any applicable local FSDO requirements.

XV. All other applicable regulations concerned with the operation 

of aircraft. 

F. Aircraft will use FCC compliant 2.4 GHz for command & control of the 

aircraft with well-defined and tested lost link procedures. 

Please advise us of any additional information or changes that may be required. 

Sincerely, 

Wes Hoffman

Managing Director - Skypoint Films, LLC.