March 1, 2016

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

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

Aviation Regulations from:14 CFR 61.113{a) & (b); 91.7(a); 91.103; 91.121; 91.151{a);

91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2};91.417{a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Eric Turner, operator of an 

Unmanned Aircraft System (UAS), hereby apply, on behalf of Mr. PM Productions LLC, for an exemption 

from the listed Federal Aviation Regulations (“FARS”) to allow commercial use of its UAS, so long as 

such operations are conducted within and under the conditions outlined herein or may be established by the 

FAA as required by Section 333. 

Applicant information:

Eric Turner

Owner

Mr. PM Productions LLC

778 South Warner Avenue

Boise, Idaho 83709

mrpmproductions@gmail.com

(208) 724-6525

Proposed UAS and Operations

Mr. PM Productions LLC will be flying the DJI Inspire 1, which is a quad copter. The DJI Inspire 1 is a 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control System (GCS) 

utilizing electronic tablet or smart phone systems. The Inspire 1 has a maximum gross weight of 6.5 

pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA 

has a maximum airspeed of 22 m/s. This will be operated over various metropolitan areas, primarily in 

Southern Idaho, to augment real estate listings, capture even aerial videography and photography, and 

related business operations. 

Mr. PM Productions LLC is requesting this exemption, which is similar to exemptions approved in 

Exemption number 12700 (Lassiter). Mr. PM Productions is requesting similar exemptions in this request 

for similar usage. 

UAS Operating Parameters

Mr. PM Productions LLC will abide by the following operating conditions under this exemption, which 

ensures a level of safety at least equal to existing rules:

• Operate UAS below 400 feet, most of the time being below 200 feet, and within a radius distance 

of 1000 feet from the controller to aid in direct line of vision observation;

• Obtain permission from the owner/ controller of any vessels, vehicles, and structures when 

operations may be conducted closer than 500 feet to such vessels, vehicles, or structures; we will 

conduct a safety assessment of the risk of operating closer to those objects and determine that it 

does not present an undue hazard;

• Operate the UAS for 5-15 minutes per flight;
• Land UAS prior to the manufacture’s recommended minimum battery power level

• Will operate UAS only during daylight hours while keeping within visual line of sight (VLOS)

• Use the UAS’s global positioning system (GPS) flight safety feature where it safely and slowly 

lands if communication with remote control pilot is lost;

• Will conduct all operations under the flight safety protocols contained in the operating documents 

and will actively ensure that all software remains up-to-date;

• Will contact respective airports if flights will be within 5 miles of operations to advise them of

flight operations

• Will operate UAS only in safe environments away that are strictly controlled, are away from 

crowds, power lines, airports, elevated light fixtures

• Will perform pre-flight inspections each time to ensure safety

• All flights will utilize a visual observer (VO). The VO will have the UAS in visual line of sight at 

all times. The pilot and VO will be able to communicate at all times during the flight. 

We have flown UAS numerous times as practice, training flights in unpopulated areas to get familiar with 

the UAS’s performance in different weather and temperature conditions. Any person operating our UAS 

will have done practice flight hours in the amount of at least 25 hours in accordance with policy 14 CFR 

61.51(b). Additionally, the person flying the UAS will have performed at least 3 takeoffs and 3 landings 

within the previous ninety days of any flight. 

I have flown 500+ hours recreationally.

Exemptions Requested

Given the size, weight, size, speed, and small operating parameters of the UA, we feel an exemption from 

14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), 

subject to certain conditions and limitations, is warranted and meets the requirement for an equivalent level 

of safety under 14 CFR part 11 and Section 333 of P.L. 112-95.

We request an exemption from § 45.23 Marking of the aircraft because the UA does not have a cabin, pilot 

stations, or cockpit to mark words or numbers. Also, the two-inch lettering would be difficult to place on 

such a small aircraft. We do have our recreational number on all aircraft.

We request an exemption from §91.7 (a) which prohibits the operation of the aircraft without holding the 

airworthiness certificate, since there is no certificate applicable to our operation, this regulation is not 

applicable. 

We request an exemption from § §91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) 

maintenance inspections because they only apply to aircraft with an airworthiness certificate. However, as 

a safety precaution, we will perform a pre-flight inspection of the UAS before every flight. 

We request an exemption from § 91.9(b) (2) which requires a manual to be onboard the aircraft. There are 

no pilots or passengers on board and the aircraft is small in size so that this regulation would be 

unnecessary. We will have the manual at the ground station to ensure maximum safety. 

We request an exemption from § 91.121 Altimeter settings as it is inapplicable because the UAS uses a 

barometric sensor and electronic GPS.

We request an exemption from § 91.151(a) Fuel requirements for flights in VFR conditions. The UAV is 

100% electric and battery alerts are issued. The UAV will be landed after the first low battery alert to 

ensure safety. We will not begin a flight without ensuring there is enough battery left to make it to the first 

intended landing with at least thirty percent battery life remaining. 
Public Interest and Public Safety

Granting the present Petition will further the public interest by allowing Mr. PM Productions LLC to 

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

agriculture, special events including but not limited to birthdays, weddings, promo events, and religious 

events. 

I thank you for your time and effort in processing this request and look forward to cooperating with the 

FAA in its continued commitment for the safe operation of UAS.

If you have questions or need additional information, please contact me at mrpmproductions@gmail.com

or (208) 724-6525. 

Sincerely,

Eric Turner

Owner

Mr. PM Productions, LLC