1

 observe productions

 1003 Hazel Ct

Chesapeake, VA 23325

 815-212-91 51

mail@observe-productions.com

June 11, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

observe production’s Petition for Exemption to Operate

Unmanned Aircraft System for Aerial Photography and Filming

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER

Henrik Weber

observe productions

1003 Hazel Ct

Chesapeake, VA 23325

815-212-91 51

mail@observe-productions.com
2

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012,

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f),

Turbine Aircraft Logistics, LLC (“Petitioner or Operator”) hereby petitions for

exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a),

91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a),

91.409(a)(1) 91.409(a)(2).

I. Petition Summary

If granted, this exemption would allow the operator to operate a small UAS (under 55lbs)

with an attached camera for the purpose of aerial photography and videography. With a

combination of factors below, the operator is confident that it can operate the UAS in a

manner equal to the safety standards set forth by the FARs for civilly manned aircraft:

• Reliability

• Return to designated point in the event of a lost control link

• Return to designated point automatically with a low battery that is dynamically

updated depending how far away the UAS is from the designated point

• Low weight

• Slow speed

• No passengers to be carried

• Experience of the crew members

• Stringent maintenance program

The operator will be operating the UAS for commercial use, providing videos and

photographs to the public without compromising safety and security. Therefor the

FAA can find good cause to grant this exemption.

II. Exemptions Requested

The operator is requesting relief from the following FAA regulations:

• FAR part 21 (Certification procedures)

• FAR 61.113 (a) and (b) (Private pilot privileges and limitations)

• FAR 61.133(a) (Commercial pilot privileges and limitations)

• FAR 91.7(a) (Civil aircraft airworthiness)

• FAR 91.9(b)(2) (Civil aircraft flight manual, markings, placards requirement)

• FAR 91.103(b)(1) (Preflight action)

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings)

• FAR 91.151 (Fuel requirements)

• FAR 91.203(a) and (b) (Civil aircraft certifications required)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

III. Operational Procedures to Satisfy Section 333

1 Unmanned Aircraft System

1.1 The UAS the operator seeks exemption for is manufactured by DJI.

This UAS is the most recent model DJI offers and was

a highly improved from what was learned from the previous highly popular

and reliable DJI Phantom series. The UAS is a 1280g multi-rotor (4

rotors) UAS with approximately 20 minutes of endurance. The UAS

purpose is to carry a small camera as its payload it has the ability
3

to be controlled by a single crewmember acting as pilot in command by

wireless remote control on a 2.4GHz band having a transmitting distance of

2km (1.08nm).

1.2 The UAS is equipped with lost link protection (referred to as “Return To

Home” (RTH) in the User Manual), allowing the UAS to

automatically climb vertically to a safe altitude to clear obstacles; then

proceed to a pre-designated point to automatically land. At anytime the UAS

and the controller reestablish link, the PIC can cancel the RTH and resume

control of the UAS. In the event of lost GPS signal, control to the UAS

is not lost. Since all operations will be conducted under Visual Line of Sight

VLOS the PIC can control the aircraft back to a safe location to land.

1.3 Because the UAS does not have the endurance to meet the

requirements of FAR 91.155(b), the operator is requesting exception from this

regulation and substituted with the following standard: All flights will be

terminated at a maximum of a 25-minute flight or when the battery level

reaches 25% (which ever occurs first).

1.4 The operator will register the UAS IAW FAR part 47. The operator’s UAS

will have identification makings in accordance with FAR 45(c). The

UAS is too small to practically display registration markings IAW FAR

45.29(a) though (e). The registration marks will be affixed as large as practical

IAW FAR 45.29(f).

1.5 The operator is requesting relief from FAR 91.121 because the UAS

is not equipped with a standard adjustable barometric altimeter system. The

UAS collects altitude information for two sources: GPS and

barometric aiding. Upon powering one the UAS, the system will reset the

altitude readout on the controllers base station to 0 feet above ground level

(AGL). The PIC then will reference the digitally displayed altitude in AGL for

the duration of the flight.

1.6 Because of the small size, low weight, slow speed, and limited operating area

of the UAS, the operator is requesting relief from CFR part 21(h)

(airworthiness certificates). The operator has determined that it can operate

the UAS to an equivalent level of safety set forth under part 21 of the

CFRs and meets the requirements set forth in the 333 exemption.

1.7 Prior to flight the UAS will be determined to be in an airworthy

condition IAW the pre-flight checklist outlined in appendix A UAS User

Manual V1.0 page 49. The operator is requesting exemption from required

inspections of FAR 91.409(a)(1) and (2) and will adopt the manufactures

recommended inspections program as outlined in the following paragraph.

Because the FAA has not established an inspection standard for UAS as have

been established for manned aircraft under FAR 43.13 appendix D, the

operator is requesting an exemption from the maintenance scope and detail of

FAR 43.13 appendix D and replaced with the manufactures recommended

maintenance program: The operator will inspect and maintain the UAS

UAS IAW DJI Maintenance Manual (See appendix B UAS

Maintenance Manual). The operator will follow the manufactures

recommended inspection interval to preform comprehensive maintenance of

the UAV every 50 flight hours or 200 flights, whichever comes first as

outlined in the UAS Maintenance Manual.

1.8 The operator will adopt maintenance record requirements set forth under FAR

91.417.
4

1.9 The DJI UAS operates on the 2.4GHz frequency band for both UAS

control as well as video downlink. The UAS and the

UAS remote controller comply with part 15 of the FCC rules (see page

appendix A, page 62 of the DJI user manual). The UAS is

equipped with a vision positioning system along with a sonar system in order

to be able to fly inside a building and still remain stable. The UAS

primary payload is a small camera mounted with a gimbal.

1.10 Refer to appendix A UAS User Manual V1.0 for more detail on the

UAS.

2. Unmanned Aircraft PIC

2.1 The operator has designated Henrik Weber as the chief pilot for its UAS operations. 

Henrik Weber has 2 years of experience with hundreds of hours with UAS for 

recreational use, always ensuring the safety of everybody around the UAS. 

2.2 The PIC will designate a Visual Observer (VO) prior to any flight to be

conducted. The VO shall be familiar with UAS operations to the

extent their designated role as VO requires. The VO will be require to be able

to communicate with the PIC verbally at all times.

2.3 It will be the PICs responsibility to review weather conditions, flight battery

requirements, and UAS performance limitations prior to conducting the flight.

3. UAS Operating Procedures

3.1 All UAS flight operations will be conducted during daylight hours.

3.2 All UAS operations will be conducted in VFR conditions.

3.3 No UAS operation will be conducted with less cloud clearance or visibly then

is allowed by FAR 91.155.

3.4 No UAS flight operations will be conducted beyond the sight of both

the PIC and the VO.

3.5 No UAS flight operation will be conducted above a vertical height of 400ft

AGL.

3.6 NO UAS flight operations will be conducted within highly populated areas.

3.7 The PIC will not fly the UAS at speeds to exceed 50KTS ground speed.

3.8 The PIC will insure that no person, other then those trained and designated by

the Chief UAS pilot in UAS operations, are within 500ft of horizontal

distance from the UAS during flight operations or while the rotors are turning.

3.9 The PIC will insure that the UAS in flight comes no closer then 500ft of

vehicles or structures, with the exception of those that are a part of the filming

operation. PIC will obtain a signed consent form from the owner or authorized

representative of any vehicle or structure the UAS in flight will come within

500ft of.

3.10 Prior to any UAS flight operation the PIC will consult current FAA

aeronautical sectional charts and airport facility directory to insure that no

flight operation will come within 5NM of an airport with a control tower,

3NM of an airport not having an operational control tower but having a

published instrument approach procedure, 2NM of an airport not having an

operational control tower or instrument approach procedure, or 2NM of a

heliport having an instrument approach procedure without having an

appropriate authorization from the ATC controlling facility and airport

manager.
5

3.11 PIC will remain clear and yield right of way to all manned aircraft

operations of all category and classes.

3.12 The PIC prior to conducting UAS flight operations will review current

conditions to insure that no flight operations will be conducted within an active restricted 

area, prohibited area or warning area.

3.13 Prior to UAS operations for the motion picture or television industry, the

operator will comply with regulations set forth in FAA order 8900.1, Volume

3, chapter 8, section 1 (Certificate of Waiver for Motion Picture and

Television Filming).

4. Conclusion

We kindly ask the FAA to exempt

observe productions under section

333 of the FAA Modernization and Reform Act of 2012. 

We are be happy to answer any questions regarding this exemption request if needed.

Via 815-212-9151 or mail@observe-productions.com. 

Thank you so much.

Sincerely,

Henrik Weber

Owner

observe productions