1001 Pennsylvania Avenue, NW, Washington, DC 20004-2595  p202 624-2500  f202 628-5116

Gerald F. Murphy

(202) 508-8855

gmurphy@crowell.com

June 29, 2015

VIA FDMS

Ms. Cheryl Collins

Program Manager, Docket Operations

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor, Room W12-140

Attn: FAA Dockets

Washington, DC 20590

Re: Razorfish, LLC – Petition for Exemption

Dear Ms. Collins:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”)1

and 14 C.F.R. Part 11, Razorfish, LLC (“Razorfish”) petitions for an exemption from the Federal

Aviation Regulations identified herein to authorize Razorfish to operate small unmanned

aircraft systems (“sUAS”) for aerial filming and photography.

2

 Razorfish’s sUAS operations will

be conducted under the safeguards described in this petition and as may be further established

by FAA.

FAA has now issued over 664 Section 333 exemptions to various commercial enterprises

for sUAS applications ranging from aerial photography and cinematography to precision

agriculture and flare stack, bridge and tower inspections.3 Indeed, FAA has granted hundreds

of Section 333 exemptions for aerial filming and photography in circumstances that are similar

in all material respects to those proposed here.4 In issuing those exemptions and other Section

 

1

Pub. L. No. 112-95, § 333, 126 Stat. 76. 

2

 This exemption request is based on the information provided in this petition and the DJI Inspire 1

user manuals (collectively, the “Manuals”), copies of which are already on file with FAA. See, e.g., In the Matter of

the Petition of 360 Productions, LLC, Grant of Exemption No. 11901 (Jun. 25, 2015), Docket No. FAA-2015-1313 (DJI

Inspire 1) (“Exemption No. 11901”).

3

See FAA, Authorizations Granted Via Section 333 Exemptions (rev. Jun. 29, 2015), 

https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/. 

4

 See, e.g., In the Matter of the Petition of Astraeus Aerial, Grant of Exemption No. 11062 (Sept. 25, 

2014), Docket No. FAA-2014-0352 (“Exemption No. 11062”); In the Matter of the Petition of CinemaCapture 

Videography, Grant of Exemption No. 11785 (Jun. 9, 2015), Docket No. FAA-2015-0952 (“Exemption No. 11785”);

In the Matter of the Petition of Replicopy, Inc., Grant of Exemption No. 11693 (May 26, 2015), Docket No. FAA2014-1030 (“Exemption No. 11693”); and In the Matter of the Petition of 4Rotor Filming LLC, Grant of Exemption 

No. 11674 (May 22, 2015), Docket No. FAA-2015-0655 (“Exemption No. 11674”).
FAA Dockets

June 29, 2015

Page 2

333 grants, FAA found that “the enhanced safety achieved using an unmanned aircraft (UA)

with the specifications described by the petitioner ... gives the FAA good cause to find that the

UAS operation enabled by this exemption is in the public interest.”

5

 The same public interest

and safety justifications apply to Razorfish’s petition, and should enable FAA to grant it on an

expedited basis.

I. Petitioner

Razorfish, part of the Publicis Groupe, is one of the world’s largest interactive digital

advertising and marketing agencies, specializing in experience design, brand marketing and

storytelling, commerce and marketing platforms, digital performance marketing, and digital

strategy and innovation services. Razorfish is at the intersection of technology, creativity and

media, and emphasizes the use of technology to deliver solutions for brands. Razorfish

combines the best thought leadership of the consulting world with the leading capabilities of

the marketing services industry to support its clients’ business needs, such as launching new

products, repositioning a brand or participating in the social world. Razorfish was recognized as

the No. 9 agency (highest-ranked digital shop) in Advertising Age’s 2013 A-List rankings and

works with 25 percent of Advertising Age’s Top 100 U.S. advertisers. 

Razorfish seeks to build on this success by leveraging sUAS in its operations. This sUAS

capability will allow Razorfish to add a new filming dimension to its business by offering high

quality filming and photography to its customers at a fraction of the cost of using a manned

fixed wing aircraft or helicopter. 

All communications regarding Razorfish’s petition should be directed to:

Jeffrey Griffin

Legal Counsel

Re:Sources USA

33 Arch Street

Boston, MA 02110

jeffrey.griffin@usresources.com

with a copy to: Gerald F. Murphy

Crowell & Moring LLP

1001 Pennsylvania Ave NW

Washington, DC 20004

gmurphy@crowell.com

II. Section 333

Razorfish’s petition is consistent with Congress’s goal set forth in Section 333 of the 

FMRA, which directs the Secretary of Transportation to consider whether certain UAS may 

operate safely in the national airspace system (“NAS”) before completion of the rulemakings

required under Section 332 of that legislation. In making this determination, the Secretary is 

required to determine which types of UAS do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the following: (1) the UAS’s size, weight, 

 

5

See, e.g., Exemption Nos. 11785, 11693, and 11674 at 2.
FAA Dockets

June 29, 2015

Page 3

speed, and operational capability; (2) operation of the UAS in close proximity to airports and 

populated areas; and (3) operation of the UAS within visual line of sight of the operator.6 To 

implement Section 333, FAA has the authority to issue exemptions from its safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the public 

interest.7

Razorfish’s proposed sUAS operations meet the requirements of, and qualify for 

expedited approval under, Section 333. Razorfish’s DJI Inspire 1 sUAS weigh less than 55

pounds, will operate at less than 400 feet above ground level (“AGL”), within visual line of sight 

(“VLOS”), at speeds of no more than 87 knots, and will generally comply with the same 

conditions and limitations FAA established in issuing previous Section 333 grants.

8

 Operations 

conducted under these safeguards will provide at least an equivalent level of safety compared 

to the current regulatory structure. Moreover, Razorfish’s operations will not “create a hazard 

to users of the national airspace system or the public or pose a threat to national security” due 

to the size of the sUAS and the restricted areas in which it will operate.9

III. Regulations from Which an Exemption is Requested

Razorfish requests an exemption from the following regulations to the extent necessary

to conduct the operations described in this petition: 

 14 C.F.R. §§ 61.23(a) and (c)

 14 C.F.R. §§ 61.101(e)(4) and (5)

 14 C.F.R. § 61.113(a) 

 14 C.F.R. § 61.315(a) 

 14 C.F.R. § 91.7(a)

 14 C.F.R. § 91.119(c)

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)(1)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. §§ 91.409(a)(1) and (2)

 14 C.F.R. §§ 91.417(a) and (b)

The following subsections describe Razorfish’s request for an exemption from each of

these regulations and demonstrate how Razorfish’s operations will provide for at least an

 

6

FMRA § 333(a).

7

See 49 U.S.C. § 106(f) and 49 U.S.C. § 44701(f).

8

See supra note 3.

9

See, e.g., Exemption No. 11062 at 8 (citing FMRA § 333(b)).
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June 29, 2015

Page 4

equivalent level of safety compared to the current regulatory structure that applies to manned

aircraft.

A. 14 C.F.R. §§ 61.23(a) and (c) – Medical certificates: Requirement and

duration

Sections 61.23(a) and (c) generally require pilots of manned aircraft to hold a FAA

medical certificate in order to exercise pilot privileges. As of March 24, 2015, however, FAA

determined as a matter of policy that operators holding a valid driver’s license in lieu of a third

class medical certificate may conduct commercial sUAS operations under a Section 333 grant.

10

 

Accordingly, Razorfish requests an exemption from these provisions to the extent necessary to

give Razorfish the same relief from medical certificate requirements that FAA has afforded to

hundreds of other operators pursuant to Section 333.

11

B. 14 C.F.R. §§ 61.101(e)(4) and (5); 61.113(a); and 61.315(a) – Pilot Privileges

and Limitations

Section 61.113(a) limits private pilots to conducting non-commercial operations.

Similarly, Sections 61.101(e)(4) and (5) prohibit a recreational pilot from acting as pilot in

command of an aircraft for compensation or hire or in furtherance of a business. Section

61.315(a) authorizes a sport pilot certificate holder to act as pilot in command of a light-sport

aircraft, subject to certain restrictions specified in Section 61.315(c), including a prohibition on

doing so for compensation or hire or in furtherance of a business, among other restrictions. 

FAA has already determined, however, that a private, recreational or sport pilot certificate is

sufficient to conduct commercial sUAS flights in a wide variety of operational environments.12 

Since Razorfish will be conducting its sUAS operations for compensation in furtherance of its

aerial filming and photography business, it requests an exemption from these provisions to the

extent necessary. Razorfish notes that FAA has provided such relief to hundreds of other

Section 333 operators.13

Consistent with the operating conditions and limitations specified in similar Section 333 

grants,14 Razorfish will utilize only pilots holding a FAA airline transport, commercial, private, 

recreational, or sport pilot certificate and at least a valid U.S. driver’s license. The sUAS will be 

operated within VLOS of the pilot-in-command (“PIC”) at all times, and all operations will utilize 

a visual observer (“VO”), who will be able to communicate verbally with the PIC at all times 

 

10

 See, e.g., In the Matter of the Petition of EnviroMINE, Inc., Grant of Exemption No. 11227 (Mar. 

24, 2015), Docket No. FAA-2014-0678 at 4, 8; see also FAA, FAA Summary Grants Speed UAS Exemptions (Apr. 9, 

2015), https://www.faa.gov/news/updates/?newsId=82485. 

11 See supra note 3.

12 Id.

13 Id.

14 See, e.g., Exemption No. 11785.
FAA Dockets

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during the operation. And because the area of operation will be controlled and restricted in 

accordance with the safeguards contained in the Manuals and the FAA-approved conditions 

and limitations described in Section VI, infra, permitting the sUAS operations as requested 

would provide for the level of safety otherwise achieved through these Part 61 provisions. 

Accordingly, grant of the requested exemption, subject to the conditions and limitations 

specified herein, would not adversely affect the safety of the NAS.

C. 14 C.F.R. § 91.7(a) – Civil aircraft airworthiness

Section 91.7(a) prohibits any person from operating a civil aircraft unless it is in an

airworthy condition. FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the

extent that the airworthiness certificate requirements of Part 2115 are waived or inapplicable. 

Such airworthiness certificate requirements are inapplicable here, insofar as Razorfish’s sUAS

provides for an equivalent level of safety when compared to manned aircraft, consistent with

the relevant language of the FMRA and the precedent FAA has established under Section 333.

16

 

D. 14 C.F.R. § 91.119(c) – Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically,

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

operate an aircraft below an altitude of 500 feet above the surface except over open water or

sparsely populated areas and that in such cases, the aircraft may not be operated closer than

500 feet to any person, vessel, vehicle or structure. As detailed in previous Section 333 grants,

however, FAA has determined that adherence to certain safety measures is sufficient to

warrant an exemption from Section 91.119(c) for sUAS operations.

17

 Consistent with the relief

provided to other sUAS operators under Section 333, Razorfish requests an exemption to the

extent necessary to permit Razorfish to operate below an altitude of 500 feet AGL and closer

than 500 feet to any person, vessel or structure. An equivalent level of safety will be achieved

given the size, weight and speed of Razorfish’s sUAS, as well as the locations where it will be

operated (i.e., at the filming site and nowhere near other aircraft). In addition, consistent with

the flexibility that FAA has already provided to other Section 333 operators for aerial filming

and photography,

18 Razorfish requests permission to operate a minimum distance of 200 feet

 

15 FAA has concluded that no exemption from Part 21, Subpart H (Airworthiness Certificates) is 

needed if the agency makes a finding under the FMRA that the UAS selected provides an equivalent level of safety 

when compared to aircraft normally used for the same application. As these criteria are met here, no exemption is 

needed. See, e.g., Exemption No. 11062 at 13-14, 22. But to the extent FAA determines that there are some 

characteristics of Razorfish’s sUAS that may not meet this standard, an exemption is requested. 

16 See, e.g., id.

17 See, e.g., supra note 3. 

18 See, e.g., In the Matter of the Petition of Team 5, LLC, Grant of Exemption No. 11158 (Jan. 29, 

2015), Docket No. FAA-2014-0783, at 16-17; In the Matter of the Petition of Picture Factory, Inc., Grant of 

Exemption No. 11178 (Feb. 18, 2015), Docket No. FAA-2014-0794, at 23; In the Matter of the Petition of Shotover 

Camera Systems, L.P., Grant of Exemption No. 11159 (Jan. 30, 2015), Docket No. FAA-2014-0784, at 12.
FAA Dockets

June 29, 2015

Page 6

from any non-participating persons so long as sufficient barriers exist to protect such persons

from debris in the event of an accident.19

E. 14 C.F.R. § 91.121 – Altimeter Settings

Section 91.121 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.” Since Razorfish’s sUAS will not be

equipped with a typical barometric altimeter, Razorfish requests relief from this provision

consistent with the relief that FAA has already granted to other sUAS operators flying at

similarly low altitudes.20 Razorfish will operate the sUAS within VLOS at or below 400 feet AGL

and provide altitude information to the PIC via a digitally encoded telemetric data feed that

downlinks from the aircraft to a ground-based on-screen display. The altitude information will

be generated by equipment installed on the sUAS, and prior to each flight a zero altitude

initiation point will be established and confirmed for accuracy by the PIC. 

 

F. 14 C.F.R. § 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.” But provided certain operational parameters are established, FAA has found that

good cause exists for granting exemptions from this provision for operations in a multitude of

contexts.

21

 

Razorfish will be operating a less than 55-pound sUAS in tightly-controlled environments

at speeds below 87 knots and within VLOS. Combined with the fact that Razorfish will not

conduct operations unless a sUAS has enough available power for the intended mission, and

will not continue unless there is at least five minutes of power remaining, relief from Section

91.151(a) is warranted, in accordance with the conditions and limitations specified in Section

VI, infra. 

G. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and

(b): Maintenance Inspections

These provisions 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

 

19 See id.; see also FAA Order 8900.1, Vol. 3, Ch. 8, Sec. 1 (allowing certain relief from 14 C.F.R. § 

119(c) in the filming context, including the 200 ft. minimum distance standard requested herein).

20 See supra note 3. 

21 Id.
FAA Dockets

June 29, 2015

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as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43

of this chapter. . .,” and that other persons shall inspect or maintain the aircraft in compliance

with Part 43. Under Section 333, however, FAA has established safety measures for certain

sUAS operations sufficient to warrant an exemption from these provisions.22

Razorfish will strictly adhere to the maintenance- and inspection-related requirements

set forth in its Manuals, which are consistent with applicable conditions and limitations

described in Section VI, infra. 

IV. Unmanned Aircraft System

Razorfish proposes to fly DJI Inspire 1 sUAS. These sUAS are battery-powered multirotors weighing less than 55 pounds that will be flown in accordance with strict operating

safeguards as more fully described in Section VI, infra, as well as those described in the

Manuals. The sUAS will operate at a speed of no more than 87 knots and have the capability to

hover, and move in the vertical and horizontal plane simultaneously. Moreover, Razorfish

notes that several of the Section 333 grants encompass operations with the same make and

model of sUAS that it seeks to operate through this petition.23

The system safety features of Razorfish’s sUAS include geofencing, a full suite of

contingency management functions, user and flight plan management and approval

functionality, and many more. These and other features will ensure the safety of persons and

property within and surrounding the limited operating area. In the event the sUAS loses

communications or its GPS signal, it will have the capability to return to a pre-determined

location and land. The sUAS will also have the capability to abort a flight in the event of

unpredicted obstacles or emergencies. A comprehensive description of Razorfish’s sUAS and its

specifications and capabilities is contained in the Manuals. 

As FAA has recognized, the limited weight of less than 55-pound sUAS significantly

reduces the potential for harm to participating and nonparticipating individuals or property in

the event of an accident or incident, and the risk to an onboard pilot and crew is eliminated

with the use of sUAS.

24

In addition, prior to each flight, the PIC will conduct a pre-flight inspection of the sUAS,

and maintenance will be performed to address any condition potentially affecting safe

operations. All maintenance and alterations will be documented in the aircraft records. The

safety guidelines specified in the Manuals address the following key areas: (1) individual parts

(e.g., remote controller, compass, parameter settings, battery, storage and transportation,

maintenance and upkeep, etc.); (2) flight environment requirements; (3) flight warnings (e.g.,

 

22

 Id.

23 See, e.g., Exemption No. 11901.

24 See supra note 3. 
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failsafe and return to home, low battery, vision positioning system, transformation function,

etc.); (4) pre-flight checklist; and (5) maintenance checks concerning the battery,

transformation system, motors, and vision positioning system.

V. Unmanned Aircraft PIC

As described above, the PIC will be a FAA licensed airman with either an airline

transport, commercial, private, recreational, or sport pilot certificate that holds a current FAA

airman medical certificate or a valid U.S. driver’s license. The PIC will also meet the flight

review requirements specified in Section 61.56 in an aircraft in which the PIC is rated on his or

her pilot certificate. And, prior to conducting commercial operations under this exemption, the

PIC will have accumulated and logged sufficient UAS-specific flight experience, including at least

12 hours on the DJI Inspire 1 sUAS before being designated to operate it commercially. 

In addition, the PIC and the VO will have successfully completed a qualification process

and a sUAS flight demonstration administered by a Razorfish-approved and -qualified pilot.

VI. Operation of the Unmanned Aircraft

Razorfish will conduct all flights under the requested exemption subject to the following 

conditions and limitations, and as further detailed in the Manuals:

25

A. The sUAS will weigh less than 55 pounds (25 kilograms), including payload.

B. The sUAS will not be flown at a ground speed exceeding 87 knots (i.e. 100 miles per 

hour).

C. Flights will be operated at an altitude of no more than 400 feet AGL. All altitudes

reported to ATC will be in feet AGL.

D. The sUAS will be operated within VLOS of the PIC and/or VO at all times. 

E. All operations will utilize a VO, who may be used to satisfy the VLOS requirement as long 

as the PIC always maintains VLOS capability. The VO and PIC will be able to 

communicate verbally at all times.

F. The grant of exemption and Manuals will be accessible during Razorfish’s sUAS 

operations and made available to FAA upon request. If a discrepancy exists between 

the conditions and limitations in the grant of exemption and the procedures outlined in 

 

25 The conditions and limitations detailed in this section are consistent with those set forth in the 

previous FAA Section 333 grants for operations similar to those Razorfish seeks to conduct through this petition. 

See, e.g., Exemption No. 11458.
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Page 9

the Manuals, the conditions and limitations in the exemption take precedence and will

be followed. 

G. Prior to each operation, the PIC will inspect the sUAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

sUAS, it will not be operated until the necessary maintenance has been performed and 

the sUAS is found to be in a condition for safe flight. The ground control station will also 

be included in the preflight inspection. All maintenance and alterations will be 

documented in the sUAS records.

H. Any sUAS that has undergone maintenance or alterations that affect its operation or

flight characteristics (e.g., replacement of a flight critical component) will undergo a

functional test flight prior to resumption of operations. The PIC who conducts the

functional test flight will make an entry in the sUAS aircraft records of the flight. 

I. Razorfish will follow the manufacturer’s sUAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. 

J. The PIC will possess either an airline transport, commercial, private, recreational, or 

sport pilot certificate, and a current FAA airman medical certificate or a valid U.S. 

driver’s license. The PIC will undergo at least 12 hours of training to ensure that he or 

she can follow these procedures. The PIC will also meet the flight review requirements 

specified in Section 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate.

K. Prior to conducting commercial operations under this exemption:

1. The PIC will have accumulated and logged, in a manner consistent with Section 

61.51(b), a minimum of: 12 hours of flying the DJI Inspire 1 sUAS or 24 flights 

accrued before being designated to operate it for commercial aerial filming and 

photography. During training, proficiency, and experience-building flights, the 

PIC will operate the sUAS with appropriate distance from nonparticipants in 

accordance with Section 91.119.

2. A flight demonstration, administered by a Razorfish-approved and -qualified

pilot, will be successfully completed and documented. This documentation will

be available for review upon request by FAA. 

L. The sUAS will be operated at least 500 feet from all nonparticipating persons, vessels, 

vehicles, or structures unless both of the following conditions are met:

1. Barriers or structures are present that sufficiently protect nonparticipating 

persons in the event of an accident; and 
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2. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that 

it does not present an undue hazard.

M. If the sUAS loses communications or loses its GPS signal, it will return to a 

predetermined location within the security perimeter and land or be recovered in 

accordance with the Manuals.

N. The sUAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the Manuals.

O. The sUAS will not be operated unless it has enough available power to conduct the 

intended operation and to operate after that for at least five minutes, or with the 

reserve power recommended by the manufacturer, whichever is greater. 

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

Authorization (“COA”) prior to conducting any operations above 200 feet AGL under the

exemption.26 

Q. All sUAS operated in accordance with this exemption 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.

R. Razorfish will follow the procedures established in the Manuals for documenting and 

maintaining records of the sUAS maintenance, preventative maintenance, alterations, 

status of replacement/overhaul component parts, and the total time in service of the 

sUAS. 

S. Each sUAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

 

26 Pursuant to its “blanket” COA, FAA will automatically grant a COA for flights at or below 200 feet 

to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during 

daytime VFR conditions, operate within VLOS, and stay certain prescribed distances away from airports or 

heliports. See FAA, FAA Streamlines UAS COAs for Section 333 (rev. Mar. 24, 2015), 

https://www.faa.gov/news/updates/?newsId=82245. This blanket COA allows flights anywhere in the country 

except restricted airspace and certain other prohibited areas, and FAA automatically issues it at the time the 

exemption is approved. Id. To the extent Razorfish plans to operate its sUAS above 200 ft. AGL, it will apply for a 

COA authorizing it to do so. 
FAA Dockets

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T. The preflight inspection section described in the Manuals will account for all 

discrepancies (i.e., inoperable components, items, or equipment).

U. Razorfish’s use of radio frequency spectrum for operation and control of the sUAS will

comply with the Federal Communications Commission (“FCC”) or other appropriate 

government oversight agency requirements. 

V. The documents required under Sections 91.9 and 91.203 will be available to the PIC at

the ground control station of the sUAS any time the aircraft are operating. These

documents will be made available to FAA or any law enforcement official upon request.

W. The sUAS will remain clear and yield the right of way to all other manned operations and

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

activities, parasailing activities, hang gliders, etc.).

X. sUAS operations will not be conducted during night, as defined in Section 1.1. All

operations will be conducted under visual meteorological conditions (“VMC”). Flights

under special visual flight rules (“SVFR”) are not authorized.

Y. The sUAS will not be operated by the PIC from any moving device or vehicle.

Z. The sUAS will not be operated less than 500 feet below or less than 2,000 feet 

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

AA.The sUAS will not be operated within five nautical miles of an airport reference point 

(“ARP”) as denoted in the current FAA Airport/Facility Directory (“AFD”) or for airports 

not denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to Razorfish. The 

letter of agreement with the airport management will be made available to FAA and any 

law enforcement official upon request.

BB. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

FAA’s UAS Integration Office (AFS-80) within 24 hours and the National Transportation 

Safety Board (“NTSB”), as applicable.

VII. Public Interest

Authorizing Razorfish to conduct aerial filming and photography using sUAS under the

conditions specified herein will bring immediate and significant safety improvement to the

marketing and advertising industry. Razorfish’s sUAS will be used to conduct aerial filming and

photography in a manner that provides at least an equivalent level of safety compared to the
FAA Dockets

June 29, 2015

Page 12

Crowell & Moring LLP  www.crowell.com  Washington, DC  New York  San Francisco  Los Angeles  Orange County  Anchorage  London  Brussels

current regulatory structure that applies to manned aircraft.

27

 Its sUAS operations will also

provide for safer and more efficient means of performing certain commercial tasks that are

currently performed by other methods.

VIII. Conclusion

Given the small size of Razorfish’s sUAS and the restricted, controlled environment 

within which it will operate, Razorfish’s proposed sUAS aerial filming and photography 

operations fall squarely within the type of operations that Congress intended be authorized 

pursuant to Section 333. They are also similar in all material respects to those that FAA has 

already authorized under Section 333, including several covering nearly identical types of 

operations – and should be approved on an expedited basis. Based on the clear direction from 

Congress, the authority contained in the Federal Aviation Act, as amended; the well-established 

equivalent level of safety present in Razorfish’s proposed operations; the significant public 

benefits associated with using sUAS to conduct aerial filming and photography; and the 

precedent that FAA has established through more than 664 Section 333 grants, grant of

Razorfish’s petition is in the public interest. Accordingly, Razorfish respectfully requests that 

FAA grant it an exemption without delay.

Respectfully submitted,

Gerald F. Murphy

Counsel for

Razorfish LLC

cc: Jeffrey Griffin

 

27 See Exemption No. 11062 at 22.