June 10, 2015 

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Aviation Regulations from certain parts of the FARs. 

Dear Administrator Huerta: 

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

and 14 C.F.R. Part 11, Len Davis, the owner of Pure Imagination, Inc, a Creative Agency, 

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

him to operate a small Unmanned Aircraft System (“sUAS”) under the conditions and 

limitations set forth in this Petition. 

The requested exemption would permit the operation of small, unmanned and relatively 

inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, 

and (3) would provide safety enhancements to the already safe aerial video production 

operations presently using manned helicopters and airplanes. Approval of this exemption 

would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish 

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

Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Len Davis 

Company: Pure Imagination, Inc 

Address: 12 E Wilson St., Batavia, IL 60510 

Telephone: (630) 406-7990 x202

Mobile: (630) 301-0090 

Email: ldavis@purei.com

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 
14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 

The Appendix describes the FARs from which an exemption is requested and summarizes the 

justification for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Administrator must determine which types of UASs do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333(c) (emphasis added). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its 

regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which 

includes sUASs. The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of the 

Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 

44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). 

The petitioner is a professional videographer, photographer and owner of a creative agency 

that has been in business for 15 years. His assignments include capturing photos and video for 

multiple clients utilizing various professional equipment for the production of educational, 

corporate, sales, promotional, training and instructional videos.

The wide availability of small Unmanned Aircraft Systems, also known as “UAS,” capable of 

carrying high-quality video cameras and priced at affordable levels intrigued the petitioner. His 

entire professional career has involved exploring new technologies and adapting them to 

capture good imagery to inform the public. In December 2014, he bought a DJI Inspire 1. He 

has flown it for a total of 40 hours for recreational purposes, exploring the potential and the 

limitations of its video subsystem. 

He is pleased with the quality of the imagery captured and has edited it into a number of 

photographic vignettes that meet his high standards for technical quality and artistic merit. 

Now, a number of clients have heard about Petitioner’s activities and have seen the results and 

are pressing Petitioner to undertake additional UAS photography and videography for 

compensation. 
He understands that this is not now permissible unless he obtains special permission from the 

FAA. Many competitors of Petitioner are actively flying sUAS to conduct aerial photography for 

commercial purposes, notwithstanding the FAA’s stated prohibition. He also notes and has 

read the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform 

Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits 

that can result from widespread deployment of sUAS technology. Accordingly, Petitioner 

applies for authorization under the Federal Aviation Act, and the FARs rules to undertake the 

following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at 

a significant competitive advantage if he, as he prefers, complies with FAA policy. 

Vehicle 

The UAS proposed for use by the petitioner is the Inspire 1 provided by DJI.com (DJI), used in 

conjunction with DJI hardware/software controllers, data signal processing, and GPS 

stabilization and navigation electronics. It weighs almost 6.5 pounds with the battery. The max 

speed is 42.7 knots. 

When GPS is available, the Home Point (the location the operator is standing) automatically 

refreshes, so the UAS always knows where the operator is even if he moves around. When the 

operator commands the UAS to return to Home Point, or in case of an emergency, the UAS 

automatically returns and lands safely.

The Inspire 1 User Manual and all of the specs can be viewed online here: 

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

Flight profiles 

The petitioner will program the UAS so that it will not fly above 400 feet above ground level, or 

more than 1500 feet away from him. He will carefully preflight the vehicle before each mission 

to assure that its compass and GPS system are properly calibrated and that the return-to-home 

feature, altitude, and radius limitations work. 

He will operate it only over largely unpopulated areas where the potential of uncontrolled 

descent to cause injury or damage is low. He will not operate it in controlled airspace. In the 

unlikely event that a manned aircraft flies below 400 feet AGL where the petitioners operating 

his UAS , he will keep both the vehicle and manned aircraft in sight and avoid the manned 

aircraft. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform 

Act relating to size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security. The Petition justifies grant 

of the requested exemptions allow the Petitioner to obtain aerial photography with his UAS.

Respectfully submitted, 

Len Davis 
Appendix

FAR section Subject Justification 

14 CFR § 

45.23(b) 

Requirement to display 

registration number on vehicle 

Insufficient space on vehicle 

14 CFR Part 

21 

Aircraft certification 

requirements and procedures 

Designed for manned aircraft; not suitable 

for off-the-shelf sUAS 

14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for manned 

aircraft, not sUAS; petition describes training 

for sUAS operator 

14 CFR § 91.7 

(a) 

Airworthiness requirement Designed for manned aircraft; not suitable 

for off-the-shelf sUAS 

14 CFR § 91.9 

(b) (2) 

Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 

91.103(b) 

Requirement for crew members 

to be onboard 

Unmanned vehicle 

14 CFR § 

91.109 

Requirement for dual controls 

during flight instruction 

No one aboard to operate controls 

14 CFR § 

91.119 

Minimum altitudes for safe flight Safety requires operation below these 

altitudes 

14 CFR § 

91.121 

Altimeter settings No one aboard to read altimeter 

14 CFR § 

91.151(a) 

Fuel requirements Vehicle does not use fuel 

14 CFR § 

91.203 (a) & 

(b) 

Requirement for registration and 

airworthiness certificates to be 

onboard 

No one aboard to read certificates 

14 CFR § 

91.205(b) 

Cockpit instruments No one aboard to read