July	29,	2015

Marc	Mulry

Owner

Centered	Films

4790	Caughlin	Pkwy	#164

Reno	Nevada	89509

775-232-6314

marc@centeredfilms.com

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	

Aviation	Regulations	from:	14	CFR	21	subpart	H

14	CFR	45.23(b)

14	CFR	61.113(a)	and	(b)	

14	CFR	91.7(a)

14	CFR	91.9(b)(2)

14	CFR	91.103

14	CFR	91.109

14	CFR	91.119(c)

14	CFR	91.121

14	CFR	91.151(a)

14	CFR	91.203	(a)	and	(b)	14	CFR	91.405	(a)

14	CFR	91.407	(a)	(1)

14	CFR	91.409	(a)(1)	and	(2)	14	CFR	91.417(a)	and	(b)	

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

For	over	ten	years,	Centered	Films	has	provided	clients	with	expertise	and	knowledge	in	the	

media	production	industry. We have	worked	on	hundreds	of	productions	over	the	past	10	years	

in	all	types	of	locations	with	a	perfect	client	and	employee	safety	record.	The	objective	of	

Centered	Films	and	our	Unmanned	Aircraft	System	(DJI	Phantom	2) aerial	operations	is	to	

provide	an	affordable,	high-quality	production	system	for	a	variety	of	governmental,	

commercial,	public,	and	residential	uses.

As	owner	of	Centered	Films,	I	Marc	Mulry,	have	safely	flown	small	RC	electric	quadcopters	

recreationally	for	approximately	3	years	without	incident.

BACKGROUND

Marc	Mulry	seeks	an	exemption	to	operate	the	DJI	Phantom	2	system for	compensation	or	hire	

within	the	United	States.	The	DJI	Phantom	2	is	a	vertical	takeoff	and	landing	(VTOL)	Unmanned	

Aircraft	(UA)	with	display	telemetry	data	built	into	the	upgraded	Futaba	14SG	radio	transmitter.
BASIS	FOR	PETITION

The	requested	exemptions	will	allow	myself	personally,	and	my	company	to	provide	aerial	

photography	&	cinematography	for	commercial	clients	while	meeting	necessary	safe	operating	

parameters	and	regulations	defined	by	the	FAA	&	other	local	and	regional	agencies.

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

and	14	CFR	Part	11,	Marc	Mulry,	operator	of	Unmanned	Aircraft	Systems	(UAS),	hereby	applies	

for	an	exemption	from	the	listed	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	

operation	of	designated	UAS,	provided	such	operations	are	conducted	within	and	under	the	

conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333.	

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	

sensors,	would	provide	professional	services	in	the	following	areas:

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	

architecture,	land	surveying,	engineering	and	other	related	professional	activities.	

2.	Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	public	

events,	cinematography	and	newsgathering.

3.	Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the	

owners	or	local	government	authority.

4.	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	

operations	in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or	

government	has	requested	it	by	contract	or	donation.

5.	Training	to	persons	individually	or	belonging	to	both	private	and/or	public	organizations	to	

increase	awareness	and	improve	safety	for	current	and	future	UAS	operations	within	the

NAS.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	designated	

UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	that	would	be	a)	

limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	exemption	would	increase	

public	awareness	of	UAS	operations	and	enhance	safety	to	aid	in	fulfilling	the	Secretary	of	

Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	“...establish	requirements	for	the	

safe	operation	of	such	aircraft	systems	in	the	national	airspace	system.”	

I	plan	to	operate	a	UAS,	the	DJI	PHANTOM	2,	which	is	comprised	of	an	unmanned	aircraft	(UA	or	

Phantom	2).	The	Phantom	2	is	referred	to	as	a	quad-copter	with	a	maximum	gross	weight	of	

about	3	pounds.	It	is	equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	by	

batteries.	The	UA	has	a	maximum	airspeed	of	16	m/s.	

Given	the	small	size	of	the	UAS	involved	and	the	restricted	controlled	environment	within	which	

they	will	operate,	the	applicant	fits	within	that	zone	of	safety	(an	equivalent	level	of	safety)	in	

which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	commercial	operations	of	

UAS	to	commence	immediately.	Also	due	to	the	size	of	the	UAS	and	the	controlled	areas	in	

which	the	relevant	UAS	will	operate,	approval	of	the	application	presents	no	national	security	

issue.	Given	the	following,	the	grant	of	the	requested	exemptions	is	clearly	in	the	public	interest:	

Marc	Mulry	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	have	the	
characteristics	and	that	operate	with	the	limitations	listed	herein.	These	limitations	provide	for	

an	exceptional	level	of	safety	to	operations.	These	limitations	and	conditions	to	which	Marc	

Mulry	agrees	to	be	bound	when	conducting	commercial	operations	under	an	FAA	issued	

exemption	including:	

1.	The	UAS	will	weigh	less	than	55	lbs.

2.	Flights	will	be	operated	within	line	of	sight	of	operator.

3.	Maximum	total	flight	time	for	each	operational	flight	will	be	20	minutes.

4.	Flights	will	be	terminated	at	15%	battery	power	reserve.

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL

5.	UAS	operator	will	be	trained	and	certified	in	the	proper	safety	and	operations	of	the	UAS.

6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	Procedures.

7.	The	operator	will	have	been	trained	in	operation	of	UAS	generally	and	received	up-to-date	

information	on	the	particular	UAS	to	be	operated	as	required.

8.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	return	

to	a	pre-determined	location	within	the	Security	Perimeter	and	land.

9.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.	

The	Reasons	Why	Granting	CENTERED	FILMS	Request	Would	Be	In	The	Public	Interest;	That	Is,	

How	It	Would	Benefit	The	Public	As	A	Whole.	

Granting	 the	 present	 Petition	 will	 further	 the	 public	 interest	 by	 allowing	 CENTERED	 FILMS	 to	

safely,	efficiently,	and	economically	perform	aerial	video	and	photography	of	real	estate,	events	

and	civic	landscape	over	certain	areas	of	the	United	States.	

Additionally,	 use	 of	 the	 DJI	 Phantom	 2	 UAS	 will	 decrease	 congestion	 of	 the	 NAS,	 reduce	

pollution,	and	provide	significant	benefits	 to	 the	economy.	Notably,	 the	benefits	of	CENTERED	

FILMS’	proposed	operation	of	 the	DJI	Phantom	2	UAS,	will	be	 realized	without	implicating	any	

privacy	issues.	

1.	The	Public	Will	Benefit	From	Decreased	Congestion	Of	The	NAS.	

The	 DJI	 Phantom	 2	 UAS	 are	 battery	 powered	 and	 serve	 as	 a	 safe,	 efficient,	 and	 economical	

alternative	to	the	manned	aircraft	traditionally	utilized	to	obtain	aerial	imagery.	By	reducing	the	

amount	 of	manned	 aircraft	 needed	 to	 perform	 aerial	 acquisitions,	 an	 exemption	 allowing	 the	

use	of	a	DJI	Phantom	 2	UAS	would	 reduce	 the	amount	of	manned	aircraft	in	 the	NAS,	 reduce	

noise	and	air	pollution,	as	well	as	increase	the	safety	of	life	and	property	in	the	air	and	on	the	

ground.	

Furthermore,	 by	 reducing	 the	 number	 of	 manned	 aircraft	 operating	 in	 the	 NAS,	 congestion	

around	 airports	 caused	 by	 arriving	 and	 departing	 aircraft	 will	 be	 reduced.	 The	 DJI	 Phantom	 2	

UAS	 do	 not	 require	 an	 airport	 to	 takeoff	 or	 land.	 Likewise,	 a	 reduction	 of	 manned	 aircraft	

conducting	aerial	video	and	 photography	missions	would	 result	in	 fewer	aircraft	 that	must	 be	

handled	by	air	traffic	control	during	the	ground,	takeoff,	departure,	arrival,	and	landing	phases	

of	flight	operations.
2.	The	Public	Will	Benefit	From	The	Safety	And	Efficiency	Of	The	DJI	Phantom	2	UAS.	

Conducting	 aerial	 acquisitions	 with	 the	 DJI	 Phantom	 2	 UAS,	 instead	 of	 manned	 aircraft,	 will	

greatly	benefit	the	public	by	drastically	reducing	the	levels	of	air	and	noise	pollution	generated	

during	 traditional	 aerial	 video	 and	 still	 photography	 flight	 operations.	 By	 using	 battery	 power	

and	electric	motors,	 the	DJI	 Phantom	 2	UAS	 produces	 no	air	 pollution,	and	is	 the	most	viable	

environmentally	conscious	alternative	to	the	cabin	class,	six	cylinder	internal	combustion	engine	

aircraft	that	are	typically	utilized	for	aerial	video	and	photography,	while	burning	approximately	

20-30	 gallons	 per	 hour	 of	 leaded	 aviation	 fuel.	 The	 DJI	 Phantom	 2	 UAS,	 while	 reducing	 the	

carbon	footprint	of	aerial	acquisitions,	also	eliminates	noise	pollution,	as	the	UAS	are	propelled	

by	battery	powered	electric	motors,	rather	than	an	internal	combustion	engine.	

By	using	 the	DJI	 Phantom	 2	UAS	 to	perform	aerial	acquisitions,	 the	 substantial	 risk	 to	life	and	

property	 in	 the	 air	 and	 on	 the	 ground,	 which	 is	 usually	 associated	 with	 traditional	 manned	

aircraft	flight	operations,	will	be	substantially	reduced	or	completely	eliminated.	Aside	from	the	

lack	 of	 flight	 crew	 members	 located	 onboard	 the	 aircraft,	 the	 DJI	 Phantom	 2	 UAS	 (weighing	

approximately	3	pounds	at	their	maximum	gross	weight	with	diagonal	dimension	of	23.2	inches,	

and	with	no	fuel	on	board),	has	less	physical	potential	for	collateral	damage	to	life	and	property	

on	 the	ground,	and	in	 the	air,	 compared	 to	 the	manned	aircraft	 that	 typically	 conduct	 similar	

operations	(weighing	approximately	6,000	pounds	with	a	wingspan	of	approximately	42	feet,	a	

length	of	34	feet,	and	a	fuel	capacity	of	180	gallons).	

3.	Performing	Aerial	Video	and	Photography	Operations	With	The	DJI	Phantom	2	UAS	Will	

Benefit	The	Economy.	

In	addition	to	being	safe	and	efficient,	the	DJI	Phantom	2	UAS	are	also	an	economical	alternative	

to	 using	 manned	 aircraft	 to	 conduct	 similar	 aerial	 operations.	 As	 such,	 operation	 of	 the	 DJI	

Phantom	 2	 UAS	 will	 allow	 United	 States	 based	 companies,	 like	 CENTERED	 FILMS,	 to	 remain	

competitive	and	contribute	 to	growth	of	 the	U.S.	economy.	Specifically,	with	 the	 rising	cost	of	

aviation	fuel	and	 the	Environmental	 Protection	Agency	 (“EPA”)	 regulatory	actions	 phasing	 out	

leaded	 aviation	 fuels,	 U.S.	 owned	 and	 operated	 companies	 must	 adopt	 new	 and	 alternative	

technology	in	order	to	remain	competitive.	Operating	the	battery	powered	DJI	Phantom	2	UAS	is	

one	such	technology	that	not	only	allows	companies	greater	operational	flexibility	compared	to	

manned	aircraft,	but	provides	such	 flexibility	without	 the	high	operational	cost	of	a	 traditional	

manned	aircraft.	

By	 operating	 the	 DJI	 Phantom	 2	 UAS,	 companies	 such	 as	 CENTERED	 FILMS,	 can	 remain	

competitive	 and	 profitable,	 and	 therefore,	 provide	 greater	 job	 stability	 to	 employees	 and	

contractors,	which	will	ultimately	contribute	to	growth	of	the	U.S.	economy.	Improved	financial	

performance	of	U.S.	companies,	through	commercial	use	of	the	DJI	Phantom	2	UAS,	provides	a	

stable	 workforce	 that	 increases	 consumer	 spending;	 improves	 local,	 state,	 and	 federal	 tax	

revenues;	 and	 allows	 companies	 to	 invest	 in	 research	 and	 development	 in	 order	 to	 remain	

competitive	both	in	the	United	States	and	abroad.	
4.	There	Are	No	Privacy	Issues.	

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	been	conducted	for	decades,	

CENTERED	FILMS’	proposed	operation	of	the	DJI	Phantom	2	UAS	will	not	implicate	any	privacy	

issues.	Specifically,	 the	DJI	Phantom	2	UAS	will	be	operated	only	in	compliance	with	operating	

documents	(i.e.,	DJI	Phantom	2	Instruction	Manual)	which	requires	property	owner	involvement	

as	 well	 as	 local	 law	 enforcement	 notification,	 and	 in	 accordance	 with	 the	 Federal	 Aviation	

Regulations,	including	the	minimum	altitude	requirements	of	14	C.F.R.	§	91.119.	

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	exemption	

and	are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	need	for	an	

equivalent	level	of	safety.	I	look	forward	to	working	with	your	office.	Please	contact	me	at	any	

time	if	additional	information	or	clarifications	are	needed.	

Thank	you	for	your	consideration	in	this	matter.

Sincerely,	

Marc	Mulry

775-232-6314

marc@centeredfilms.com

Link	to	DJI	Phantom	2	Manual:		Click	on	link	below

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf