April 6, 2015 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: GEE Productions Petition for Exemption to Operate Unmanned Aircraft Systems for Aerial 

Photography and Videography.

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, 

GEE Productions hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

herein and any other necessary to allow its operation of small Unmanned Aircraft Systems (UAS) to 

provide aerial photography, videography and photogrammetry services. The requested exemption 

would permit the operation of DJI Spreading Wings S800 and S900 UAS to obtain aerial photographs and 

video for mapping, marketing, structural inspections, and real estate sales.

BACKGROUND

Ron Gee founded GEE Productions in 1989 and began producing professional grade photography for 

marketing and advertising. Mr. Gee’s professional background includes education as a 

photographer/video producer and has built and flown radio control aircraft for the past 15+ years. All of 

these skills enable him to produce high quality reliable multirotor aircraft for professional aerial 

photography. Because of the current regulatory environment, sales have been limited to hobby use 

customers. GEE Productions would like to expand operations and provide professional aerial 

photography and videography services to businesses and individuals. GEE Productions carries a $1 

million business liability insurance policy to cover personal injury and/or property damage during 

production. 

The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable than 

conventional aircraft running on combustible fuel, operates at lower altitudes with no people on board 

and will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 15 minutes, this offers little 

or no risk to national security. 
THE UNMANNED AIRCRAFT (UA)

DJI Spreading Wings S900 

 S900 Airframe 

-Professional grade 

-Under 20 pounds takeoff weight 

-6 motors 

-7 to 15 minute flight time depending on battery size 

 DJI A2 - Flight Controller with GPS 

Provides Fail Safe features that allow the aircraft to return to the launch point and land 

automatically in the event the command and control signal is lost or the battery has reached a 

pre-determined threshold. If battery reaches a critical level, the aircraft will descend and land at 

the current location. Control of the aircraft is maintained during descent to allow the PIC to 

guide it to a safe landing. 

Home Lock function allows safe return of the aircraft in the event of a motor failure.

Contains a database of airports and restricted airspace and automatically prevents operation in 

these areas.

 DJI 5.8 GHz Video Downlink Transmitter – FCC Licensed. 

 DJI iOSD Mark II - On Screen Display of Telemetry. 

The iOSD Mark II superimposes telemetry data on the video downlink to provide the pilot with 

heading, speed, height, distance, GPS information, and current battery voltage as well as 

indicating proximity to airports and restricted airspace. Direction back to launch point is also 

indicated.

DJI Spreading Wings S800 EVO 

 S800 EVO Airframe 

-Professional Grade 

-Under 18 pounds takeoff weight 

-6 motors 

-7 to 15 minute flight time depending on battery 

 DJI A2 – Flight Controller. Same as S900

 DJI 5.8 GHz Video Downlink (same as S900) 

 DJI IOSD Mark II Telemetry (same as S900) 

GROUND STATION EQUIPMENT
The ground station equipment is comprised of a dual control and audio communication equipment. 

 Primary controller is for the Pilot in Command (PIC) 

-2.4 GHz radio control unit (FCC Licensed) 

-5.8 GHz video receiver (FCC Licensed) 

-Display of video and telemetry 

 Camera Controller operates the camera gimbal and does not affect aircraft control 

-2.4 GHz radio control unit. (FCC Licensed) 

-5.8 GHz video receiver (both PIC and Cameraman receive the same signal) 

-Display of video and telemetry 

-Directional antenna for improved video reception. 

GROUND CREW 

 Pilot in Command (PIC). 

 Camera Operator (optional). The Camera operator controls the camera onboard the 

aircraft for photography and videography missions. 

 Visual Observer (VO). The visual observer will provide additional situational awareness 

during flight operations. 

OPERATIONAL PARAMETERS

1. The UAS will weigh less than 55 pounds. 

2. Flights will be operated within visual line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

Flights will be terminated at 25% battery power reserve should that occur prior 

to the 15 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet (122 meters) 

AGL. Unless a specific COA is obtained, the limit will be according to the 

“blanket” COA of 200 feet (61 meters). 

5. Minimum crew for each operation will consist of the UAS pilot and the Visual 

Observer. 

6. PIC will also have accumulated and logged at least 25 hours total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS and 5 hours in the same make and model of UAS proposed 

under this exemption request. Local AMA flying fields and rules will be used to 

accumulate flying time and practice emergency procedures. PIC will also remain 

current for the type of aircraft for which the PIC is licensed. 

7. Written and/or oral permission will be obtained from the property owner. 

8. Pilot and observer will be able to communicate by voice at all times during 

the operation. Communication may be assisted by VHF or UHF radio when 

necessary. Text communications are not allowed. 

9. The UAS will only be operated during daytime hours in VFR weather 

conditions. 

10. Operations may not be conducted aboard a moving device or vehicle. 

11. Operation near airports will be conducted according to the “blanket” COA 

unless another COA is obtained. 
 5 nautical miles (NM) from an airport having an operational control 

tower; or 

 3 NM from an airport with a published instrument flight procedure, 

but not an operational tower; or 

 2 NM from an airport without a published instrument flight procedure 

or an operational tower; or 

 2 NM from a heliport with a published instrument flight procedure 12. 

Maximum speed 50 knots. 

PRE-FLIGHT CHECKLIST

1. Weather conditions are suitable for VFR flight and wind is 15 mph or less. 

2. Measure battery voltage to make sure batteries are sufficiently charged 

before takeoff. 

3. Verify that all wiring connections are tight. 

4. Raise and lock all rotor arms. Inspect for cracks, damage, and loose hardware. 

5. Check to make sure propellers are secure and free from dirt, cracks and chips.

6. Install main battery and check balance. 

7. Turn on camera equipment. 8. Verify all switch positions on the RC 

transmitters. Generally they are all in the forward position with the exception of 

the Mode which should be set to “GPS”. 

9. Turn on radio control transmitters and video equipment. 

10. Connect the UAS main battery. Check for radio connection with RC 

transmitters and video downlink. 

11. During warmup, check the A2 Flight Controller LED indicator. One green 

flash indicates GPS mode. Wait for both of the following LED indications: 

a. A string of 10 or more green flashes indicating that the forward 

direction has been recorded.

b. 2 or less red flashes to indicate that 5 or more GPS satellites have 

been obtained. This may also be observed in the video telemetry 

information. 

12. Announce your intention to take off by announcing “CLEAR”.

(full checklist provided as an attachment)

DOCUMENTATION

The following documents are attached and provided to support this petition. 

 DJI Spreading Wings S800 EVO User Manual Version 1.10

 Spreading Wings S900 User manual Version 1.2 

 A2 Flight Controller System User Manual Version 1.22

 GEE Productions Preflight Checklist 
SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN EXEMPTION 

A. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. 

part 21, Subpart H, the airworthy condition of the UAS will be the responsibility of the 

PIC in accordance with 14 C.F.R. § 91.7(b). 

B. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas 

This regulation establishes safe altitudes for operation of civil aircraft over areas other 

than congested areas. GEE Productions requests relief from this section with respect to 

persons involved in the operation as well as vehicles and structures. The UAS will not be 

operated above 400 feet altitude. It will be operated in a defined area where people and 

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

C. 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 UAS does not have a 

barometric altimeter, an exemption is requested. The UAS Flight Controller utilizes GPS 

equipment aided by a static pressure sensor to determine and maintain altitude. The 

aircraft altitude above the takeoff point is provided in the video downlink telemetry 

information and provides sufficient information for the PIC to maintain altitudes at or 

below the 400 foot (122 meter) limitations. April 6, 2015 Page 6 

D. 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 cursing 

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.” Given that the UAS aircraft only fly for a maximum of 

30 minutes and typically carry about 15 minutes of batter power, an exemption is 

requested. The UAS operations are always conducted within a few minutes of the 

takeoff and landing point and within a restricted area. GEE Productions believes that 

terminating the flight with 25% remaining battery power provides an equivalent amount 

of safety that is intended by section 191.151(a). 

E. 14 C.F.R. § 91.405(a) Maintenance Required; 

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative 

maintenance, rebuilding or alteration; 

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections; 

14 C.F.R. §§ 91.417(a) and (b) Maintenance Records 

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 the sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to the Petitioner. 

Maintenance will be accomplished by the operator pursuant to the Owner’s Manuals. 

An equivalent level of safety will be achieved because these small UAS 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 feet AGL. The operator will ensure that the UAS is in 

working order prior to initial 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. The FAA issued exemption to these regulations in Exemption 

No. 11062. April 6, 2015 Page 7 

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Petitioner: GEE Productions

Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 

91.151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b)

Description of Relief Sought: GEE Productions seeks relief from the requirements of 14 

C.F.R. §§ 61.113(a) and (b); 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); 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) to operate small unmanned aircraft 

systems (UAS) for the purpose of aerial photography and videography. 

Respectfully Submitted,

Ronald Gee

Owner

GEE Productions

5640 Highland Ct.

West Des Moines, IA 50266

Phone: 515-710-0535

ron@rongee.com