Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (t and 14 

CFR Part 11, Fourpoint Media LLC, a limited liability corporation registered in the State 

of Oregon (henceforth referred to as Fourpoint Media or Fourpoint), a commercial 

cinematography and production company and operators of Small Unmanned Aircraft 

Systems (“sUAS”), hereby apply for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAS, so long as such 

operations are conducted within and under the conditions outlined herein or as my be 

established by the FAA as required by Section 333. 

Fourpoint Media requests exemption from the below listed FARs for the purpose of 

operating our privately owned sUAS, which are equipped with digital video cameras for 

the following commercial purposes:

 1. Aerial video and/or photography for public and/or private use including but not 

limited to cinematography for television, motion picture and all reasonably 

assumed subsets of the two.

Fourpoint Media currently operates one (1) sUAS but has plans to include more sUAS, 

operating for the same above stated purposes, to it’s inventory in the future and would 

like to request exemption for not only the current sUAS being operated by Fourpoint 

Media but all future sUAS to be operated by Fourpoint Media.

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 CFR 61.113 (a)

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) & (b) 

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 
The sUAS currently owned and operated by Fourpoint Media is manufactured by China 

based Da-Jiang Innovations Science and Technology Co., Ltd (referred to as DJI) and is a 

motor-rotor single operator sUAS with the model name of PHANTOM 2. The sUAS has 

the following specifications -

• Total weight less than 55lbs including payload (actual weight without payload is 

2.20462)

• Flight time of 25mins maximum

• Ability to hover independently of operator control

• Horizontal and vertical movement

• Diagonal length of 350mm

• Maximum Ascent speed of 6m/s

• Maximum Descent speed of 2m/s

• An effective range of 3280ft

• “Return to Home” safety feature to safely land the sUAS in the case of operator error 

and or/incapacitation

Fourpoint Media operates the sUAS under strict guidelines to ensure the safety of the 

operating crew, on set personal, bystanders, property and the general public.

Fourpoint Media operates the sUAS in the following manner -

• One (1) designated sUAS operator/pilot

• One (1) to two (2) spotters/visual observer

• Spotters work to ensure that the fight path is clear and safe before, during and after 

flight.

• Spotters work with operator to map out the sUAS flight path before sUAS flight.

• Spotters and Operator communicate with hands free personal Two-way Radios and all 

times during flight.

• sUAS operates at all times at no more than 400ft above ground level (AGL)

• sUAS operates at all times within line of sight of the Spotter(s) and the sUAS Operator

• All persons involved with the operation of the sUAS, including but not limited to - 

sUAS operator, spotters, on set personnel (cast, crew, observers) will have given 

written or verbal consent to be positioned within the effective sUAS flight path and/or 

operating area before sUAS flight commences.

• The operator and spotter(s) will be trained in the operation of sUAS and will maintain 

constant communication during operation of sUAS. 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for 

the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the 

size and limited operating area associated with the aircraft to be utilized by the Applicant, 

an exemption from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the 

sUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and 

under the requirements and in compliance with local public safety requirements. The 

FAA will have advance notice of all operations. These safety enhancements provide a 

greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which 
the word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering 

will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAS will see the identification of the sUAS as “Experimental.” 

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a), 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. Our sUAS do not carry any pilots or passengers nor property therefore I am 

seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will not 

ensure remote control piloting skills. The risks attendant to the operation of sUAS is far 

less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel 

the operation and limitations set forth in the FOM will equate to the safe operation of the 

sUAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance and use of safety check lists 

prior to each flight an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) 

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, 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. The sUAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where 

the pilot flying the sUAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 
This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided 

for the aircraft an exemption will be needed. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. sUAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control is accomplished through the use of a control box 

that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. The equivalent level of safety 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and 

by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which filming is planned, an exemption may be needed 

to allow such operations. As set forth herein, the sUAS will never operate at higher than 

400 AGL with the exception that in circumstances where the sUAS is used to survey or 

photograph a structure whose height exceeds 400 feet AGL, the sUAS will not be 

operated more than 100' above the highest point on the structure. It will however be 

operated in a restricted area with security perimeter, where buildings and people will not 

be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where it is operated. No flight will be taken without the permission 

of the property owner or local officials. Because of the advance notice to the property 

owner and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 
operations of the sUAS will ensure separation between these small- UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires 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.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “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.” 

The battery powering the sUAS provides approximately 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 10 minutes in length. Given the limitations on the sUAS’s 

proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. Operating the small UAS, in a tightly controlled area where only 

people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights 

to 10 minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 

30 minutes or 25% of battery power— whichever happens first. This restriction would be 

more than adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 
The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: (1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section 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. 

The sUAS fully loaded weighs no more than 55 lbs. and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents 

or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook. An 

equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods 

of time. If mechanical issues arise the sUAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the sUAS is in working 

order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the sUAS Manufacturer's Manual, as referenced in the 

Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure 

that the sUAS is in working order prior to initiating flight and perform required 

maintenance needed. 
Fourpoint Media will operate in accordance with all Federal, State and Local ordinance, 

regulations and guidelines. 

Fourpoint Media believes it has provided sufficient and adequate cause to be granted the 

above requested exemptions for the operation of sUAS and the betterment of their 

business.

Sincerely,

Josh Williams

Owner - Fourpoint Media