Docket Number: FAA-2015-2640

11.81a

September, 20, 2015 ; formerly submitted June 3, 2015

John E. Tremba

DBA Straight Up Photography

404 Stadium Road

Connellsville, PA 15425

724-366-7767 jatremba@cvzoom.net

724-366-8485

Federal Aviation Administration

www.regulations.gov

Dear FAA: Brittany Newton: Thank you for giving me the opportunity to modify my petition. 

I am requesting an exemption from specific rules within the FAA Modernization and Reform Act 14 

C.F.R. 11 section 333. for aerial photography and cinematography utilizing light weight sUAS in the 

industrial inspection (pipelines, windmills, power lines, buildings), private real estate promotions, and 

closed set major motion picture / television recording. 

11.81b

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21; 45.23(b); . 61.113(a) & (b); 61.101 9e) (4) (5); 61.23; 

14 C.F.R. 61.133(a); 91.7(a); 91.9(b)(2) & (c); 

14 C.F.R. 91.103; 

14 C.F.R. 91.119; 91.151(a);

14 C.F.R. 91.203(a) & (b);91.405(a); 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); . 91.417(a). 

Section 11.81 What information must I include in my petition for exemptions.

11.81 c

My company owns three UAVs, a DJI Phantom 2 vision Plus, Phantom 3, and Inspire 1. All three are 

under 7 pounds in gross weight, will not fly anywhere near 100 mph., have GPS homing devices, 

battery volume controls, non zoom cameras, ability to fly in up to 30 mph winds, and use specific 

frequencies for radio transmissions. These and all the other specs of my vehicles can be viewed in the 

attached links. 

http://m.dji.com/product/inspire-1/spec http://m.dji.com/product/phantom-3-professional/spec

45.23 (b): In reference to the size and speed of my UAVs I would expect relief from the requirement of 

aircraft registration and all the accompanying letters and numbers on my craft. Additionally, the words 

“experimental”, “restricted”, et al. Would not be necessary and therefore relieved. 

I am asking for relief from Sections 61.101 (e) (4) (5), 61.113 (a) (b) as I am not a certified private or 

commercial pilot. My piloting skills reflect 20 years of flying remote control aircraft of all sorts and 

engine types. I know the capabilities of my three UAVs and fly within those parameters. As you can 

see from the descriptions of my vehicles they are quite small compared to manned helicopters and/or 

airplanes. Manned aircraft over a closed set movie scene poses a definite hazard to any or all who 

work under them. Fuel leakage, noise, risk to on-board pilots and passengers, occupying higher levels 

of the NAS all lead one to believe that UAVs are much safer, less expensive of an investment from the 
movie makers or others employing the craft, and more convenient for the total process whether it is 

inspecting windmills / industrial sites, real estate, or making movies. I am currently enrolled in UAV 

University having completed the first half of the course for UAV pilot certification and soon to 

complete the flight portion. 

Because I own a valid Pennsylvania drivers license representing a medical card, I feel I should get 

relief from sections 61.23 as well. 

61.133; I need relief from having to be a commercial pilot in order to be PIC.

91.7(a): Limited relief; As the PIC I still have the responsibility to cancel a flight for any structural, 

electrical, or mechanical reasons I see fit. 

91.9(b) (2): Limited relief needed; manuals and markings are downloaded and available in UAV 

carrying cases 

91.9(c): If I get relief from 45.23 then 91.9 becomes moot.

91.103 Limited relief. Before any flight for any occasion there is always a check of weather, 

including wind, precipitation, battery limiting cold temperatures, and LOS visibility. 

91.119 Relief from this parameter in that it limits minimum altitudes referencing large manned aircraft 

as opposed to 3-7 pound UAVs limited maximum altitude. 

91.151 Change these parameters to fit UAVs. My three vehicles all have “return home” GPS 

capabilities and battery reserve recognition. LOS loss is also a return home feature of the DJI 

machines. 

91.203 Several portions of this section need relieved. Manufacturers (DJI) always inspect and pre-fly

all their products before declaring them airworthy outside the realm of the normal manned aircraft 

inspectors. Normal warranties should suffice as “posted” certifications inside the aircraft. 

91.405 The same relief is needed for this section as described in 91.203

91.407 91.409 91.417 All portions of these sections refer to inspections and following manufacturer 

rules Manned aircraft undergo periodic inspection by outside certified mechanics while the new UAV 

industry depends upon the operator PIC to do all inspections and manufacturer endorsed maintenance 

including parts that fail at certain hours of use and circuitry that needs revamping after set hours of 

operation. Posted certificates may not be available in the UAV world. Limited relief is requested here 

to exchange normal manned aircraft postings to be super ceded by UAV manufacturer rebuilds and 

returns for maintenance. 

11.81d and e narrative

When inspecting industrial objects there is no one near the operation of the aerial vehicle. Most 

objects are set in rural locations (forests/ mountain tops). I operate with LOS only and record data 

separately from the flying machine controls. I have been flying RC planes and copters for over 20 years 

and have a great feel for the machines. The tallest windmills are under 400 feet. I do pre-flight 

inspections and always conform to the action at hand with safety my first goal. I am the only PIC. 

Daylight is my only operating environment. Never am I within 5 miles of an airport.
The jobs that I could perform for energy generating companies, oil and gas line distribution, rurally

based high tension electric lines, real estate inspections and industrial business building surveys are all 

in great demand by the public in various and subjective ways. Windmills require either dangerous man 

lifts, expensive cranes, or human climbers to inspect the turbines of windmills risking injury and 

requiring costly time and machines. Lightweight UAVs such as the ones I own are perfect for those 

inspection jobs and when considering the risk involved at least as safe if not safer than traditional 

methods. No other people would be around the windmill except me, the PIC, and a windmill technician 

who would be aware of all dangers and safety practices such as predetermined flight plans and safety 

hats, goggles, etc. . Cost and time savings might be passed on to customers. Much of the damage noted 

by the UAV could be repaired long before it became chronic and debilitating to the machines, pipes or 

wires. The industrial companies have obvious benefits, but some other industries would run more 

efficiently as well using UAVs. TV and radio stations could inform their patrons of detours to escape 

road hazards, accidents, and construction. Fire fighters could assess damage to burned out warehouses 

and forests before sending in human resources. Search and rescue efforts can be magnified by the use 

of drones. Hard to sell large acreage plots can be displayed online for prospective clients of real estate 

companies. Potential home or commercial building purchasers can inspect roofs and chimneys as well; 

All from the safety of their homes. A variety of sensors other than cameras can be added to UAVs for 

infra red, sound, vibration, electrical, and a bevy of other signals important to our highly technical 

society. Small businesses can reap the harvest of potential customers seeing the establishment from the 

air especially if the business is in a difficult to navigate neighborhood. All of these services can be 

accomplished with little or no hazard to people on the ground if permission and warnings are secured. 

Before and while I am operating my photography business, I have been employed in the burgeoning 

major motion picture business in Pittsburgh, PA. For the last 7 years I have been a member in good 

standing of IATSE local 489 as a movie grip. I am familiar with all safety procedures taken while 

recording major motion pictures. No matter how intricate a stunt or scene everyone on set is tuned to 

the safe operation and completion of the scene. Recently, I have been asked to record several scenes 

from my UAVs by a number of production companies, the most recent, Sony Productions, on the new 

TV series, The Outsiders. Although I am capable of working well within the realm of safety our 

organization requires, and I possess an IRS EIN number (47-2705246) for my company, a 

Pennsylvania Dept. of State business entity number (4323628), and a 2 million dollar liability insurance 

policy (Westfield BOP 3546907), I have declined to tape the scenes because I am not permitted under 

FAA rules to perform such services. The director has assured me that everyone who is on the set or near 

it would be fully notified of the flight plans and the area affected. All safety procedures would be in 

place. Practice flights would be flown to rehearse and look for potential problems. Eventually, the 

company found a pilot from Kentucky with an FAA exemption to tape the scenes I mentioned. The 

safety measures taken those days were beyond anything I have witnessed in the movie business these 

past 7 years. I am requesting an exemption from those rules and sections so that I can practice my 

photography profession. Movie patrons and TV viewers would enjoy and critique the scenes as would 

the artists controlling the sets. Manned helicopters or fixed wing aircraft are thousands of pounds 

heavier than my UAVs, use liquid flammable fuel, make ear splitting noise and disturb the ground area 

near the scene with turbulence. The manned aircraft are just that: manned. If there is an accident 

pilots and passengers get hurt or killed not to mention people on the ground. If a 5lb. Drone crashes in 

the forest where no one can hear it, does it really make a noise? 

Among others my exemption requests are for the requirement to have an airworthiness certification 

because DJI has an excellent reputation for quality products and verifiable testing. I request an 

exemption for having an airman certificate. Because there are no set FAA rules about pilot licensing 
for UAVs I enrolled in the UAV University in Phoenix AZ. I completed the first half of the certificate 

program, an online course revealing all the diversity of UAVs and how a number of sensors can be used 

for data transfer along with safety and best practices. The second half is a three day practicum in 

Florida where I could prove my experience and skill set to the instructor. That class is somewhere in 

my future as I am consumed by my work and business at this time. Thank you for your time and 

consideration. 

Sincerely, 

John E. Tremba, Straight Up Photography