JCreativeStudio, LLC.

Elm Grove, Wisconsin

www.jcreativestudio.com

July 30, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

JCreativeStudio, LLC’s Petition for Exemption to Operate 

Unmanned Aircraft Systems for Aerial Photography and Filming

FAA Regulatory Docket 

NAME AND ADDRESS OF PETITIONER 

JCreativeStudio, LLC.

ATTN: John Shih

1150 Pilgrim PKWY

Elm Grove, WI 53122

jshih@jcreativestudio.com

Direct Phone: 206-915-6734

1150 Pilgrim PKWY

Elm Grove, WI 53122

414-810-6734

photos@jcreativestudio.com
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JCreativeStudio, LLC.

Elm Grove, Wisconsin

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I. PETITION SUMMARY 

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), 

JCreativeStudio, LLC. (“Petitioner”) 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), 91.407(a)(1) 91.409(a)(2), 91.417(a)-(b). The 

proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted 

unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of closedset filming of motion pictures, music videos, web videos, corporate videos, television 

programs and commercials, wedding and entertainment venue videos, and still 

photography. 

Based on the small size of Petitioner’s UAS, the qualifications and experience of 

Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner 

will operate, the requested exemptions fall squarely within the zone of safety envisioned by 

Congress and set forth in Section 333. Additionally, the enhanced safety achieved by 

replacing significantly larger manned aircraft carrying crew and flammable fuel with small 

UAS carrying no passengers or crew and operated under the specific guidelines and 

procedures proposed by Petitioner gives the FAA good cause to find that the UAS 

operations enabled by the instant Petition are in the public interest. Thus, the requested 

exemptions should be granted.
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JCreativeStudio, LLC.

Elm Grove, Wisconsin

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Attachments: These attachments are too large for submission via the submission portal. 

They are available at this website for viewing or download. 

http://www.dji.com/product/inspire-1/download

1) Inspire 1 User Manual (EN) v1.2 2015-05-14

2) Inspire 1 Quick Start Guide (EN) v1.2 2015-05-14 

3) Inspire 1 Safety Guidelines v1.0 2014-12-31 

II. BACKGROUND

For more than 4 years, Petitioner have provided photography and cinematography 

services for weddings, concerts, conferences and other public and private events around 

the state of Wisconsin. Combining the latest photography and cinematography technology 

with a long track record of safe and successful projects, Petitioner’s technical expertise has 

been relied upon for photography and live event projects of a wide variety. In order to 

continue to provide the highest level of service, and to promote safety by eliminating the 

need for large manned aircraft at events, Petitioner seeks regulatory exemptions that will 

allow Petitioner to employ camera-mounted UAS technology in the photography and 

cinematography services. 

III. STATUTORY AUTHORITY

A. Section 333
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Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the 

National Airspace System (“NAS”). Section 333(a) states that the FAA “shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system 

before completion of the [comprehensive] plan and rulemaking required by section 

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operational authorization.” The FAA has committed to complying with this mandate by 

granting several petitions almost identical to the one at hand. 

See, e.g., Exemption No. 11062, Regulatory Docket No. FAA-2014-0352 (granting 

regulatory exemptions to Astraeus Aerial for operation of unmanned aircraft systems for the 

purpose of filming for the motion picture and television industry). 

Section 333(b) identifies several factors that the FAA should consider in determining 

whether commercial UAS operations should be approved. These include UAS that, “as a 

result of their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users of the [NAS] 

or the public or pose a threat to national security.” See Section 333(b). 

B. Section 44701(f) 

In addition to the specific authority conferred by Section 333, the FAA Administrator has 

general authority to grant exemptions from the FAA’s safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest. 

See U.S.C. § 44701(f). 
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IV. REQUESTED EXEMPTIONS

Petitioner requests relief from the following regulations: 

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and 

changing design approvals, production approvals, airworthiness certificates, and 

airworthiness approvals. 

Section 61.113 prescribes that “no person who holds a private pilot certificate may act 

as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft,” (see Section 61.113(a)), and that “a private pilot may, for 

compensation or hire, act as pilot in command of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; 

and (2) The aircraft does not carry passengers or property for compensation or hire,” (see 

Section 61.113(b)). 

Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, 

including a provision impliedly limiting to persons holding a commercial pilot certificate the 

ability to act as pilot in command of an aircraft “[f]or compensation or hire.” 

Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft 

unless it is in an airworthy condition. 

Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 
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Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, 

before beginning a flight, become familiar with all available information concerning that 

flight, to include, “For any flight, runway lengths at airports of intended use, and the 

following takeoff and landing distance information: ... For civil aircraft for which an approved 

Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is 

required, the takeoff and landing distance data contained therein.” 

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: “Over other than congested 

areas. An altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure.” 

Section 91.121 requires, in pertinent part, 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.” 

Section 91.151(a) prescribes that no person may begin 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 cruising 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. 

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless 

it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective 
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U.S. registration certificate issued to its owner or, for operation within the United States, the 

second copy of the Aircraft Registration Application as provided for in § 47.31(c). 

Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless 

the airworthiness certificate or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall 

have the aircraft inspected as prescribed in subpart E of the same part and shall, between 

required inspections, except as provided in paragraph (c) of the same section, have 

discrepancies repaired as prescribed in Part 43 of the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft 

that has undergone maintenance, preventative maintenance, rebuilding, or alteration 

unless it has been approved for return to service by a person authorized under § 43.7 of 

the same chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the 

issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that -

(a) Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventative maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 
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airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include- 

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revisions date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required. 
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(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired and 

the aircraft is approved for return to service. 

V. PETITIONER’S PROPOSED OPERATIONS SATISFY SECTION 333.

A. Unmanned Aircraft System

The UAS to be operated under this request are less than 55 lbs. fully loaded, will be 

operated at a speed of no more than 50 knots, carry neither a pilot nor passenger, carry no 

explosive materials or flammable liquids, and operate exclusively within a secured area. 

Petitioner’s UAS use a radio frequency spectrum for operation and control that complies with 

Federal Communications Commission (“FCC”) requirements, and Petitioner has integrated 

safety features into the UAS, as described in Inspire 1’s User Manual, Quick Start Guide, and 
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Safety Guidelines (collectively “Flight Operations and Procedures Manual” also known as

“FOPM”).

The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 104 Ounces (2935g) designed 

primarily to carry aloft a high definition camera. It has an advertised maximum speed of less 

than 43 knots (22m/s) and a maximum climb rate of less than 1200 feet per minute (5 m/s). It 

is powered by four electric motors with a distance between motors of less than 18 inches 

(438mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time 

video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from 

PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either 

loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 22 

minutes maximum. The onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination of flight and landing 

will be initiated when the battery reaches a predetermined low state. It is anticipated that flights 

will usually last less than 15 minutes. More information is available in attachment 1 or at 

http://www.dji.com/product/inspire-1. Thus, good cause exists for granting Petitioner’s 

requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for flight in VFR 

conditions). 
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Petitioner’s UAS will be identified by serial number, registered in accordance with 

14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. 

Part 45, Subpart C. Markings will be as large as practicable. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), 

Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter 

onboard the UAS. Instead, altitude information will be provided to the UAS PIC via a digitally 

encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen 

display. The altitude information will be generated by equipment installed onboard the UAS, 

using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requested 

relief from 14 C.F.R. § 91.121. 

Given the size, weight, speed, and limited operating area associated with the aircraft to 

be utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H 

(Airworthiness Certificates), subject to certain conditions and limitations, is warranted 

(if necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. 

Part 11 and Section 333. The UAS operated without an airworthiness certificate in the 

restricted environment and under the conditions and limitations proposed by Petitioner will be 

at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the 

proposed limitations and conditions. 
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Petitioner will strictly comply with safety and maintenance procedures included in all 

applicable UAS manufacturer’s instructions and operating manuals. To the extent such 

information is not included in the guidelines developed by the manufacturers, Petitioners will 

develop and document maintenance, overhaul, replacement, and inspection requirements, 

procedures to document and maintain maintenance records with regard to Petitioner’s UAS, 

and UAS technician qualification criteria. Petitioner’s FOPM will include maintenance 

requirements for Petitioner’s UAS, including “on-condition” maintenance and modifications. In 

light of these mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b) are warranted. 

B. UAS Pilot in Command 

Petitioner’s UAS pilot in command (PIC) shall have passed the FAA ground school 

examination but shall not be required to hold a current pilot’s license. Since there are no 

standards for either private or commercial UAS pilot certificates, knowledge of airspace 

regulations acquired from FAA ground school and dexterity in the control and operation of the 

UAS acquired from actual operation of the aircraft will be the most important factors in 

establishing an equivalent level of safety. According to the FAA, “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the 

airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and 

model experience, culminating in verification through testing.” See Exemption No. 11062, 

Regulatory Docket No. FAA-2014-0352, at p. 18. With those factors in mind, Petitioner’s UAS 

PIC shall be required to meet several conditions: 
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• The UAS PIC will have accumulated and logged a minimum of five-hours of flight time 

with the specific make and model of the UAS to be utilized for operations under the 

exemption and three take-offs and landings in the preceding 90 days. 

• The UAS PIC will have successfully completed the qualification process as specified in 

the operations manuals, to include a knowledge and skill test.12

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s 

understanding that Petitioner’s UAS will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore 

unnecessary. To the extent such an exemption is deemed necessary, Petitioner asserts that it 

should be granted in light of the safety procedures proposed herein. In accordance with the 

pertinent part of 14 C.F.R. § 91.7(b), the operator in command of Petitioner’s UAS shall be 

responsible for determining whether the aircraft is in a safe condition for flight. Petitioner’s 

manuals for maintenance and operations shall include safety checklists to be used by the 

operator in command prior to each flight. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight 

manual, marking, and placard requirements and § 91.203(a) and (b), (Civil aircraft: 

certifications required), it is Petitioner’s understanding that relief from these regulations is no 

																																																							 1 Prior to operating, the PIC will be required to pass the knowledge and airmanship test 

qualifications developed by Petitioner for the UAS (which will be included in Petitioner’s 

FOPM). There are no established practical test standards that support a jurisdictional FAA 

FSDO (“Flight Standards District Office”) evaluation and approval of company designated 

examiners. Petitioner will conduct these tests in accordance with its FOPM. Given the 

constraints of the proposed operations, this procedure for testing will not adversely affect the 

safety of the NAS.
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longer necessary in light of the FAA Memorandum “Interpretation regarding whether certain 

required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 

2014. 

To the extent the FAA deems an exemption from this section necessary for Petitioner’s 

proposed operations, such exemption should be granted in light of the mitigating fact that 

Petitioner will maintain the documents required under 14 C.F.R. §§ 91.9 and 91.203 at the 

UAS ground control station during flights. 

Additionally, 100% of Petitioner’s operations will utilize a visual observer (“VO”). The VO 

may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and the PIC will be able to communicate verbally at all times during 

operational flights. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply 

with the other applicable procedures and requirements stated in § 91.103(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before initiation of 

a flight. The PIC will also account for all relevant site-specific conditions in their preflight 

procedures. Risks presented by sun glare will be mitigated by the PIC’s and VO’s ability to see 

other air traffic and initiate a return-to-home sequence if needed. 

The PIC’s UAS operation will be limited to a unique and restricted environment. Given the 

(1) separation of private photography and filming operations from other manned operations, (2) 

parallel nature of aeronautical knowledge requirements incumbent in the FAA ground school 

exam and the process of obtaining a private pilot’s license, and (3) the proposed UAS 
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airmanship skills of Petitioner’s PICs, the additional manned airmanship experience of a 

private pilot would not correlate to the airmanship skills necessary for Petitioner’s proposed 

unmanned operations. Thus, Petitioner’s request for relief from 14 C.F.R. § 61.113(a) and (b) 

and § 61.133(a) should be granted. 

C. Operating Parameters of Petitioner’s UAS 

Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce and raise 

awareness of the beneficial uses of small unmanned air systems. So long as such operations 

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

FAA as required by Section 333. 

Petitioner’s UAS operations will be conducted within an event’s predetermined and access 

controlled environment. In this controlled environment, Petitioner’s operations will remain 

within VLOS of the PIC and VO, below 400 feet AGL, and at speeds below 50 knots. Flights 

will be operated at a lateral distance of no less than 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or nonparticipating persons. The UAS will operate in accordance 

with the safety and operational requirements of the FOPM. Prior to the operation, a Safety Risk 

Analysis Plan (“SRAP”) will be created which includes all safety and operational information 

necessary to safely carry out the flight. When applicable, all UAS operations will be conducted 
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in accordance with any state or local privacy laws. Only participating persons at the event will 

be permitted within the operating area.3

Consistent with the relief typically provided to manned operations under FAA Order 8900.1, 

Volume 3, Chapter 8, Section 1, Petitioner requests relief from 14 C.F.R. § 91.119(c) with 

respect to those participating persons, vehicles, and structures directly involved in the 

performance of the actual filming. Regarding distance from participating persons, the FOPM 

set forth safety factors for authorized and consenting production personnel. Because those 

procedures are specific to participating persons, no further FSDO or aviation safety inspector 

approval is necessary for reductions to the distances specified in Petitioner’s manuals.

Regarding the distance from nonparticipating persons, Petitioner will ensure that no 

persons are allowed within 500 feet of the operating area except those consenting to be 

involved and necessary for the event, with the possibility of reducing this distance to no less 

than 200 feet if it would not adversely affect safety and the Administrator has approved it. This 

is consistent with FAA Order 8900.1, V3, C8, S1. 

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center 

of a non-towered airport unless a letter of agreement with that airport’s management is 

obtained and the operation is conducted in accordance with a Notice to Airmen (“NOTAM”). 

Additionally, Petitioner will not operate in Class B, C, or D airspace without written approval 

																																																							 3 Pursuant to Order 8900.1 V3, C8, S1, “participating persons” includes all persons associated 

with the filming production. Participating persons will be briefed on the potential risk of the 

proposed flight operations and must acknowledge and accept those risks prior to participation. 
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from the FAA. Nor will Petitioner operate the UAS less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

Petitioner’s UAS will remain clear and yield the right of way to all manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders). 

Although Petitioner seeks to comply with the waiver process as described in FAA Order 

8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and 

Television Filming), the current section of Order 8900.1 has specific processes that preclude a 

jurisdictional FAA FSDO from issuing the required Certificate of Waiver, because the section 

did not originally provide for UAS operations. Thus, Petitioner seeks exemption from the 

applicable regulations normally waived during that process. Petitioner proposes that the FAA 

include the required notifications and coordination with jurisdictional FSDOs through the 

conditions and limitations accompanying the requested exemption, and that the exemption 

sought herein will take the place of the Certificate of Waiver normally issued by a jurisdictional 

FSDO under 8900.1. Under this rubric, Petitioner will notify every FSDO with jurisdiction over 

the area that Petitioner plans to operate, just as with manned filming operations, and those 

FSDOs will have the ability to coordinate further conditions and limitations with the UAS 

Integration Office to address any local concerns. 

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or 

Authorization (“COA”) prior to conducting any operations under this grant of exemption. In 

fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not 

more than 72 hours in advance, but not less than 48 hours prior to the operation. 
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D. The Requested Exemption Promotes the Public Interest 

The enhanced safety achieved by replacing significantly larger manned aircraft carrying 

crew and flammable fuel with small UAS carrying no passengers or crew and operated under 

the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to 

find that the UAS operations enabled by the instant Petition are in the public interest. 

Moreover, as the FAA has already recognized, “UAS provide an additional tool for the wedding 

and event industry, adding a greater degree of flexibility, which supplements the current 

capabilities offered by manned aircraft.” See Exemption No. 11062, Regulatory Docket No. 

FAA-2014-0352, at p. 22. Operations for this petition will enable our business to create 

calming, relaxing films for hospital, clinics and other facilities in line with our current ground 

based projects. Additionally, this petition will allow our business to provide service for property 

owners or their designees seeking an enhanced perspective for characteristics, amenities, and 

benefits of their desired photographic subjects that cannot be displayed through ground level 

videography/photography. Aerial photography is a valuable marketing tool that can lead to 

increased commerce and enhance personal photography. Crop surveying applications could 

lead to decreased use of pesticides and fertilizer and conservation of water as well as 

increased crop yields and decreased costs. Aerial surveying and inspections can increase 

work site efficiency, improve volumetric estimations and reduce risks. The petitioner will 

provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an 

independent contractor. A visual observer will be utilized. Valid liability insurance has been in 

effect. Flight data including UA flight time, Control Unit operation time, incident, accident, and 

details concerning any deviations from normal operations will be available to FAA for use in 
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collecting data regarding the use of UAS as part of this application. This data may be 

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as 

required. 

V. CONCLUSION

For the foregoing reasons, the regulatory exemptions requested herein should be granted 

and Petitioner should be permitted to conduct small UAS operations for the purposes of “aerial 

photography, cinematography, videography, mapping, crop surveying, inspections and other 

flight operations”. The primary purpose of seeking this exemption is to obtain the capability to 

offer those services while remaining in compliance. 

Respectfully submitted,

JCreativeStudio, LLC.

By John Shih

John Shih

Owner 

JCreativeStudio, LLC.