February 22, 2015

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11, Drone Tech Aerial Cinematography (DTAC) seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the following described Remotely Piloted Aircraft

Systems (RPAS), which includes the remotely piloted aircraft or rotorcraft, ground based 

equipment and operators. The requested exemption would support an application for a 

commercial Certificate of Authorization (COA) to use the following RPASs to support the 

following operations: Aerial Filming/Photography, Motion Picture and Television, Aerial 

Surveying and Real Estate Filming/Photography.

Regarding the Unmanned Aircraft System 

a) Petitioners should describe how the proposed UAS operation will be safely conducted to 

minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners 

should describe the design and operational characteristics for the type(s) of UAS they intend 

to operate, e.g. aircraft performance and performance limitations, operating procedures, and 

aircraft loading information in as much detail as possible. This could be provided in the 

petition or in an Aircraft Flight Manual or similar document.

DTAC utilizes an array of multiple size rotorcraft to enable operators to utilize the smallest 

aircraft possible for the job requirement, thus minimizing potential risk. Please review the 

following document, “Aircraft Quick Reference Guide”, for a more detailed look at the various 

aircraft to be operated. In addition manufacturer supplied manuals have been provided along 

with this submission. Here is a brief explanation of the RPASs in general:

The Remotely Piloted Aircraft Systems (RPAS)

a) Rotorcraft range from a fully loaded weight of 3lbs to <55lbs, are battery operated, range 

from having 4 motor to 8 motor rotorcraft, has a vertical takeoff and landing capacity 

(VTOL), are manufactured by DJI and Gryphon Dynamics, Models: DJI Phantom2, DJI 

Inspire1, DJI S900, Gryphon Dynamics X8 and have been equiped by DTAC to carry the 

following equipment in flight:

b) An on-board flight management suite with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller. Has the 

ability to enter into a “failsafe” mode so that it may return to the launch area safely in the 

Drone Tech Aerial Cinematography

ATTN: Jaron Denson

34135 Mulholland Hwy

Malibu, CA 90265

PH: (310) 748-9978
event of a loss of link. Loss of GPS enables a failsafe that allows the rotorcraft to do a 

controlled landing at its current location.

c) An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video.

d) An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter, back to the Pilot In Command (PIC) including Altitude 

(AGL), horizontal and vertical speed, compass direction of flight and direction back to 

the aircraft launch site.

e) A 500mW, 5.8GHz ISM band on-board radio transmitter that transmits live video from 

the on-board camera plus all the flight data from the telemetry system described above.

a) A 2.4GHz ISM band radio receiver that receives commands from the PIC to control the 

RPAS while in flight.

Ground Based Equipment

b) A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the RPAS

while in flight.

c) A 5.8GHz video receiver that displays live video and flight data from the on-board 

camera and fuses it all together onto a screen for the PIC to monitor during flight 

operations.

Operators

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

end and who controls and is responsible for the safe operation of the RPAS while in the 

air and on the ground. PIC is also responsible for certifying the airworthiness of the 

RPAS and performs maintenance when required.

b) A Visual Observer (VO) is a trained person who provides a second pair of eyes to 

visually track and aid in see and avoid while RPAS is in flight. The Visual Observer is 

within verbal communication range of the PIC for the extent of the flight.

2. Petitioners should describe any procedures they would implement, such as pre-flight 

inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. 

This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and 

Inspection Manual, or similar document.6 Rev. 9/25/2014 NOTE: The Aircraft Flight 

Manual and Maintenance and Inspection Manual may be separate documents or combined in 

a single document.

NOTE: Any Document That is Listed Under Drone Tech Aerial Cinematography (DTAC)

Documentation is Considered Proprietary to DTAC’s Operation and in NOT for public 

Release.

Please refer to the following documents submitted along with this petition:
Drone Tech Aerial Cinematography follows checklist oriented procedures for Pre-Flight, Flight, 

Post Flight, Emergency Issues and Maintenance and Repair. All maintenance and repairs are to 

be performed by a DTAC authorized technician and all issues or discrepancies will be logged in 

the appropriate aircraft log book. A checklist style approach combined with appropriate 

documentation will ensure safe flight operations. These checklist and logbooks are always on site 

and available to the PIC during every operation and are available upon request.

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the 

UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and 

whether it complies with Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. NOTE: Petitioners should be able to provide the 

FCC approval letter or show compliance with FCC requirements upon request.

Please review, “Aircraft Quick Reference Guide_DTAC_REV0_021815.pdf”. All aircraft utilize

FCC compliant PIC command links and video links.

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly 

responsible for the operation of the UAS, including information such as: the level of airman 

certificate held; any applicable training related to the operation; and any minimum hours of 

Drone Tech Aerial Cinematography Documentation

Item File Name

Operations Checklist Operations Checklist_DTAC_REV0_021415.pdf

Maintenance and Inspection 

Manual

Maintenance and Inspection Manual_DTAC_REV0_021615.pdf

Aircraft Performance 

Data/Limitations/Loading

Aircraft Quick Reference Guide_DTAC_REV0_021815.pdf

Aircraft Logs Logs_DTAC_REV0_021415.pdf

Manufacturer Documentation

Item File Name

Phantom2 Operations Manual PHANTOM2_User_Manual_v1.4_en.pdf

Inspire 1 Operations Manual Inspire_1_User_Manual_v1.0_en.pdf

DJI S900 Operations Manual S900_User_Manual_v1.2_en.pdf

Gryphon Dynamics X-8 Gryphon Dynamics-X8.pdf

DJI A2 Flight Controller Operations 

Manual

A2_Quick_Start_Guide_v1.2_en.pdf
flight experience required by the PIC(s), both total flight time and the time with the 

particular UAS. If the operation would use visual observers, petitioners should describe their 

roles and qualifications. 

5. 5. Petitioners should describe the medical standards and certification of the PIC(s) directly 

responsible for the operation of the UAS.

As previously stated by the FAA in prior exemptions, Drone Tech Aerial Cinematography 

will comply with the following:

a) The PIC must possess at least a private pilot certificate and a third-class airman 

medical certificate. The PIC must also meet the flight review requirements specified 

in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate.

b) DTAC may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria (200 flight cycles and 25 hours of total time as a UAS rotorcraft 

pilot and at least 10 hours logged as a UAS pilot with a similar UAS type, 5 hours in 

the make and model UAS authorized under this exemption), training program, and 

currency requirements (three take-offs and three landings in the preceding 90 days). 

The PIC must also demonstrate 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 must be 

logged in a manner consistent with 14 CFR § 61.51(b). The VO is also required to 

complete the operator’s training requirements. A record of training must be 

documented and made available upon request by the Administrator. Flights for the 

purposes of training the operator’s PICs and VOs (training, proficiency, and 

experience-building), are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119

c) The RPAS will only be operated in the field with both a PIC and a VO in accordance 

with current FAA Policy.

Regarding the Operation of the Unmanned Aircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe 

how the proposed operation(s) would not adversely affect safety, or how they would provide a 

level of safety at least equivalent to that provided by the rule from which exemption is sought. 

Petitioners should address any plans to implement clearly defined operational borders and 

procedures to ensure public safety, which includes persons and property both in the air and on 
the ground. This can be described in the petition, in an Operations Manual, or similar document. 

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, 

NAS safety considerations, and the safety of the non-participating persons and property during 

the operational period and within the operational area. 

a) DTAC’s intended operations will be limited to the following: Aerial 

Filming/Photography, Motion Picture and Television, Aerial Surveying and Real Estate 

Filming/Photography. Additionally, we request that we be allowed to support our local 

community and use our systems with prior consent to benefit first responders who might

require assistance, including Fire Fighters, Police, Sheriff, Search and Rescue ect.., while 

remaining subject to all limitations cited in this application.

b) All DTAC’s Remotely Piloted Aircraft Systems are powered by batteries, are smaller, 

lighter, quieter and more maneuverable than larger manned aircraft running on 

combustible fuel. DTAC’s aircraft operate at lower altitudes with no personnel on board 

and will thereby reduce current risk levels and thereby enhance safety and diminish the 

likelihood of death or serious bodily injury. With relatively small payload as compared to 

its manned counterparts and maximum flight time not exceeding 30minutes, DTAC’s

aircraft and procedures offer little to no risk to national security, the public and NAS.

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe 

minimum flight visibility and distance from clouds for their intended operation(s). Petitioners 

should describe potential hazards and safety mitigations associated with these proposed 

conditions. These issues can be addressed in the petition, an Operations Manual, or similar 

document. 

Please review attached documents for the requested information: “Operations 

Checklist_DTAC_REV0_021415.pdf” and “Aircraft Quick Reference 

Guide_DTAC_REV0_021815.pdf”. Aircraft will not to be operated above 500ft AGL.

8. Petitioners should describe the characteristics of the area of intended operation(s) and the 

associated potential hazards, in accordance with the statutory mandate under Section 333 7 Rev. 

9/25/2014 regarding proximity to populated areas. These issues can be addressed in the petition, 

an Operations Manual, or similar document.

As stated before in similar cases approved by the FAA, Drone Tech Aerial Cinematography will

comply with the following:

a) The UA may not be operated over congested or densely populated areas. Ultimately, it is the 

PIC’s responsibility to maintain the minimum safe altitudes required by § 91.119.

b) Regarding distance from nonparticipating persons, the operator must ensure no persons are 

allowed within the perimeter of 500 feet from the area of primary filming except those 

consenting to be involved and necessary for the filming production. This provision may be 

reduced to no less than 200 feet if it would not adversely affect safety and the Administrator 

has approved it. For example, an equivalent level of safety may be determined by an aviation 
safety inspector’s evaluation of the filming production area to note terrain features, 

obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating 

persons (observers, the public, news media, etc.) from debris in the event of an accident. This 

is also consistent with the same FAA Order 8900.1, V3, C8, S1. 

c) All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained prior to the beginning of every 

flight.

9. Petitioners should describe if they intend to operate in the proximity of any airports, in 

accordance with the statutory mandate under Section 333 regarding proximity to airports.

Drone Tech Aerial Cinematography will not operate within the proximity of 5 miles of an airport 

unless the appropriate prior written authorization is given for such operations. DTAC will 

comply with prior rulings from the FAA conditions and limitations:

a) The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart 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) as required by the operator’s Air 

Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA). The 

letter of agreement with the airport management must be made available to the 

Administrator upon request.

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to 

comply with his mandate. 

Drone Tech Aerial Cinematography will only operate its rotorcraft within unaided VLOS of the 

PIC and the designated Visual Observer (VO). PIC and VO will be within verbal communication 

range. Only one VO is allowed to work with the PIC during a flight.

11. Petitioners should describe any procedures they would implement for conducting a preflight 

safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 

91.7(b)) and that the planned operation can be completed safely. These procedures can be 

addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar document. 

Please see the following submitted documents, “Operations 

Checklist_DTAC_REV0_021415.pdf”, “Maintenance and Inspection 

Manual_DTAC_REV0_021615”. Additionally PIC and owner of Drone Tech Aerial 

Cinematography (Jaron J Denson) has 5 years of experience engineering, repairing,

manufacturing and flying RPASs for a US DOD contractor, holds a M.S. Mechanical 

Engineering, B.S. Physics and is qualified to repair and certify aircraft for safe flight in the NAS.
12. If petitioners intend to conduct operations which have existing requirements to notify Flight 

Standards District Offices (FSDOs) prior to operations – such as motion picture and television 

filming, or pipeline and powerline patrol – petitioners should describe their intended 

coordination in this regard for their proposed operation(s). 

As previously stated by the FAA in similar cases, Drone Tech Aerial Cinematography will 

comply with the following FAA conditions and limitatinos:

At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed 

filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of 

activities must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 23 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

Drone Tech Aerial Cinematography herby requests an exemption from the following FAR’s:

Section 61.113(a) and (b) prescribes that—

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC 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.
Drone Tech Aerial Cinematography’s PIC will hold a Private Pilots Certificate and third class 

medical certificate to conduct commercial operations. In the case of RPASs the FAA has ruled in 

the past that a private pilots certificate will suffice as an equivalent level of saftey for 

commercial operations of a remotely piloted aircraft.

Section 91.7(a) prescribes that –

No person may operate a civil aircraft unless it is in an airworthy condition.

Drone Tech Aerial Cinematography has produced and presented its own documentation in 

conjunction with manufacturer documentation to ensure that the associated rotorcraft are 

operating in an airworthy condition. Airworthiness will be declared by the PIC any discrepancy

or issues that arise will be documented in the aircraft repair logs and repaired by a DTAC 

authorized technician or OEM manufacturer depending on complexity of repair.

Section 91.119(c) prescribes that –

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: 

(c) 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.

Drone Tech Aerial Cinematography desires to operate below 500ft AGL in order to complete low 

level aerial missions and remain out of airspace potentially occupied by manned aircraft. DTAC will 

operate under our own safety protocols which include:

a) Operating in a controlled environment where risk will be mitigated by being aware of 

surrounding obstacles, airports and actively populated areas by reviewing VFR charts and 

directing any questions or concerns to the appropriate FSDO.

b) Performing safety briefs with all participating personnel.

c) Posting signs or personnel to keep public away from flight operations.

d) Performing modifications as necessary to any of our documentation, protocols or checklist to 

update or enhance safety protocols.

e) Contact appropriate airports or FSDO as appropriate if the operations are within 5 miles of an 

airport and advise them of our operations and get prior written consent where applicable to 

our operations.

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.‖

Drone Tech Aerial Cinematography’s PIC has live aircraft position data through the RPAS’s 

command link, GPS based altitude data is available to the PIC at all times. There is no provision 

on the aircraft for a traditional altimeter. The AGL reading of the altitude should provide an 

equivalent level of safety in keep the aircraft within intended airspace.

Section 91.151 prescribes, in pertinent part, that –
(a) 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.

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at 

least 20 minutes.

Drone Tech Aerial Cinematography will comply with the following to achieve an equivalent level of 

saftey:

a) Operate rotorcraft during official daylight hours and not operated within 500 feet below or 

2000ft horizontally from a cloud or when visibility is less than three miles for the PIC.

b) Takeoff only when there is enough power to fly the first point of intended landing and 

assuming normal cruise speeds, land the RPAS with 25% battery power remaining.

Section 91.405(a) requires, in pertinent part,

that an aircraft operator or owner shall have that 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) prescribes that no person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for 

return to service by a person authorized under § 43.7 of the same chapter.

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

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

certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, 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, preventive 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 that 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 revision 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) 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 shall be retained until the defects are repaired and the aircraft is approved 

for return to service.

Drone Tech Aerial Cinematography has submitted documentation and procedures that outlines 

the process for required inspections and aircraft maintenance logs to account for the repair of 

aircraft issues and discrepancies.

Additionally Drone Tech Aerial is aware that the FAA has submitted conditions and limitations 

on similar exemption request and DTAC is able and willing to fully comply with those same 

conditions and limitations with our own aircraft and their corresponding limitations.

Drone Tech Aerial Cinematography is willing to modify or amend any part of this request to 

satisfy the need for an equivalent level of safety. Please contact us at any time if you require 

additional information or clarification. We look forward to working with your office.

Sincerely, 

Jaron J Denson

Drone Tech Aerial Cinematography

310-748-9978