1

November	2, 2015	

U.S.	Department	of	Transportation, Docket Operations

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590

RE:	Petition	to	the	FAA	for	Section	333	Exemption	

Dear	Sir	or Madam:	

Chop	 Shop	 Pictures,	 LLC	 dba	 Raptor	 Aerial	 Systems	 hereby	 submits	 to	 the	

Federal	 Aviation	 Administration,	 pursuant	 to	 the	 FAA	 Modernization	 and	

Reform	Act	of	2012,	an	exemption	for	petition,	in	accordance	with	Section	333	

of	the	Act.	

This	letter	provides requested	information	as	listed	in	the	FAA’s	“Public	Guidance	

for	Petitions	for	Exemptions	Filed	under	Section	333”.	

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	Background:	

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	is	video	production	company	

that	has	been	in	business	for	more	than	ten	years.	It	is	comprised	of	video	editors,	

photographers,	videographers,	writers	and	producers	offering	video	creation	

services	for	corporate	and	broadcast	clients.	

Purpose	for	the	Exemption

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems’ requested	exemption	would	

permit	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	to	operate	SUASs	under	

controlled	conditions	in	airspace	that	is	(1)	limited	(2)	predetermined	(3)	controlled	

as	to	access,	and	(4)	would	provide	safety	enhancements	to	the	already	safe	

operations	of	those	aircraft	of	similar	size,	weight,	speed,	and	operating capability.		

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems’ exemption	request	would	

permit	its	commercial	operation	of	SUAS	for	aerial	photography	and	videography	in	

tightly	controlled	and	limited	airspace.	Aerial	photography	and	videography	services	

will	be	offered	to	homeowners,	realtors,	builders,	contractors,	and/or	inspectors	for	

use	in,	but	not	limited	to,	real	estate marketing,	safer	inspections	of	home	and	

building	exteriors	and	closed	set	filming.	All	operations	will	be	conducted	on	private	

property	and	with	the	written	and/or	oral	permission	of	the	property	owner(s).	

Operations	will	always	be	conducted	in	areas	that	are	clear	of	all	people,	except	the	

pilot	in	command	(PIC)	and	the	Visual	Observer.	Such	operations	will	ensure	that	

the	SUAS	will	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	

public.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	operation	will	not	differ	

significantly	from	the	situation	described	in	Grant	of	Exemption	No.	12205	(FP	

AeroSolutions,	LLC).	
2

Contact Information

John	Robinette

Chop	Shop	Pictures,	LLC

dba	Raptor	Aerial	Systems

324	Crepe	Myrtle	Lane

Murphy,	TX	75094

jr@chopshoppictures.com	

List	of	Specific	Section	of	14	CFR	for	which	exemption	is	sought:

The	listing	matches	the	list	on	page	7	of	the	FAA’s	“Public	Guidance	for	Petitions	

Filed	Under	Section	333”,	Rev. 9/25/2014

14	CFR	21,	Subpart	H	– Airworthiness Certificates

14	CFR	61.113	(a)	and	(b),	Certification:	Pilots,	Flight	Instructors,	andGround	

Instructors

14	CFR	91.7(a),	Airworthiness	required	for	operation	

14	CFR	91.105,	Flight	crewmembers	at	stations

14	CFR	91.119(c),	Minimum	safe	altitudes	

14	CFR	91.121,	Altimeter	settings

14	CFR	91.151,	Fuel	requirements	for	flights	in	VFR	conditions	

14	CFR	91.405	(a),	Maintenance required

14	CFR	91.407	(a)(1),	Operations	after	maintenance	

14	CFR	91.409	(a)(1)	and	(2),Inspections

14	CFR	91.417	(a)	and	(b),	Maintenance records

Section	333	of	the	Reform	Act	grants	the	Secretary	authority	to	determine	(1)	if	an	

unmanned	aircraft	system,	as	a	result	of	its	size,	weight,	speed,	operational	capability,	

proximity	to	airports	and	populated	areas,	and	operation	within	visual	line	of	sight	

(VLOS)	does	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	

national	security,	and	(2)	whether	a	certificate	of	waiver,	certificate	of	authorization,	

or	airworthiness	certification	under	49	USC	44704	is	required	for	the operation of

civil (non-governmental)	UASs.	Therefore,	if	the	Secretary	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.
3

OperationOverview

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems’	SUASs	are	quadcopters	

weighing	7	or	fewer	lbs.	(including	payload).	The	SUASs	have	the	capability	to	

hover	and	move	in	the	vertical	and	horizontal	planes	simultaneously.	They	will	

operate	only	in	visual	line	of	slight	(VLOS)	and	will	operate	only	in	tightly	

controlled	and	limited	airspace.	They	are	capable	of	operating	at	speeds	of	up	to	42	

knots,	but	will	be	routinely	operated	at	much	lower	speeds.	They	will	routinely	be	

operated	below	200	feet	above	ground	level	(AGL),	and	never	above	400	feet	AGL.

Aircraft

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	operates	Inspire	1	SUASs	

manufactured	by	DJI, a	well-known leader in multirotor technology. DJI strives to

bring new	perspectives	to	aerial	work	to help	companies accomplish	feats	safer,	

faster and	with	greater	efficiency.	They	have	an	unparalleled	commitment	to	R&D,	a	

culture	of	constant	innovation,	and	a	focus	on	transforming	complex	technology into	

easy-to-use	devices.

The	standard	Inspire	1	quadcopter	package	includes	the	Inspire	1	itself,	camera,	

gimbal,	propulsion	system,	flight	control	system,	5.8	GHz	remote	controllers,	and	

2.4	GHz	Wi-Fi communication	system.	The	remote	uses	a	5.8	GHz	frequency to

prevent interference	with	the	video/telemetry	channel.	This	second	channel	allows	

for	a	constant	connection	with	the	Inspire	1	to	monitor	it	via	an	iPad	that	is	attached	

to	the	remote	controller.

The	Inspire	1	is	about	18	inches	square	in	size.	It	has	a	maximum	ascent	speed	of	

10	knots,	a	maximum	descent	speed	of	8	knots,	and	a	maximum	flight	speed	of	42	

knots.	While	operating	within	VLOS,	the	remote	control	has	a	range	of	5km.	The	

total	weight	(including	the	payload)	is	approximately	6.5 lbs.

The	Inspire	1 is	equipped	with	a	DJI	flight	control	system.	This	provides	for	

incredible	ease	of	use	and	stability.	Pilots	can	control	the	Inspire	1’s	movements	in	

many	directions	– including	pitch	(forward	and	backward),	roll	(left	and	right),	

elevator	(up	and	down),	and	yaw	(turn	left	or	right).	The	flight	control	system	can	

also	provide	Intelligent	Orientation	Control	(IOC),	failsafe,	battery	level	warnings,	

and	show	the	aircraft’s	current	heading,	direction,	and	approximate	distance	from	

home on the	on-screen radar. The	built-in	GPS system aids in stabilizing the aircraft	

and	automatically	and	safely	returns	it	back	to	its	home	point	in	any	case	where	

communication	between	the	remote	control	and	multirotor	are	lost.

The	Inertial	Measurement	Unit	(IMU)	has a	built-in	inertial	sensor	and	a	barometric	

altimeter	that	measures	both	attitude	(ATTI)	and	altitude.	The	inertial	measurement	

tells	the	Inspire	1	how	it’s	tilted.	And	the	gyros	tell	it	if	it’s	rotating	in	any	particular	

direction.
4

The	Inspire	1’s	compass	reads	geomagnetic	information	and	assists	the Global	

Positioning	System	(GPS)	to	accurately	calculate	the	position	and	height	of	the	

aircraft. The vertical hover accuracy is .5m.	The	horizontal	hover	accuracy is	2.5m

The	Inspire	1	has	LED	flight	indicators	on	the	ends	of	each	of	its	four	rotor	arms.	The	

LEDs	illuminate	to	indicate	the	status	of	the	flight	control	system	and	alert	the	PIC	of	

any	possible issues.

Such	highly	advanced	capabilities	will	ensure	that	the	SUASs	can	be	safely	operated	

and	“not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.”

Equivalent	Level	of Safety

In	an	effort	to	join	the	FAA	in	its	mission	to	provide	the	safest,	most	efficient	

aerospace	system	in	the	world	and	to	minimize	the	risk	to	the	NAS	or	to	persons	and	

property	on	the	ground,	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	agrees	

to	be	bound	by	the	following	limitations	and	conditions	when	conducting	commercial	

operations	under	an	FAA	issued	exemption:

A. For	the	purposes	of	ensuring	SUASs	will	be	operated	within	the	standards	that	

the	FAA	has	allowed	in	the	AMA	National	Model	Aircraft	Safety	Code	

(Attachment:	“AmaSafetyCode.pdf”	document.):

1. SUASs	will	not	be	flown:

a. In	a	careless	or	reckless	manner.

b. At	a	location	where	SUAS	activities are	prohibited.

2. SUAS	pilots will:

a. Yield	the	right	of	way	to	all	human---carrying aircraft.

b. See	and	avoid	all	aircraft	and	a	spotter	must	be	used	when	

appropriate.

c. Not	fly	higher	than	400	feet	above	ground	level	or	within three

(3)	miles of	an	airport	without	notifying	the	airport operator.

d. Not	interfere	with	operations	and	traffic	patterns	at	any	airport,	

heliport	or	seaplane	base	except	where	there	is	a	mixed-use	

agreement.

e. Not	exceed	a	takeoff	weight	of	55	pounds	(including payload).
5

f. Ensure	the	aircraft	is	identified	by	affixing	the	owner’s	contact	

information	to	the	outside	of	the	SUAS.

g. Not	operate	SUASs	while	under	the	influence	of	alcohol	or	while	using	

any	drug	that	could	adversely	affect	the	PIC’s	ability	to	safely	control	the	

model.

h. Not	operate	SUASs	carrying	pyrotechnic	devices	that	explode	or	burn,	or	

any	device	that propels	a	projectile	or	dropsany	object	that	creates	a	

hazard	to	persons	orproperty.

3. SUASs	will	not	be	flown	unless:

a. The	 aircraft,	 control	 system	 and	 pilot	 skills	 have	 successfully	

demonstrated	 all	 maneuvers	 intended	 or	 anticipated	 prior	 to	 the	

specific event.

b. An	experienced	pilot	assists	an	inexperienced	pilot.

4. All	pilots	shall	avoid	flying	directly	over	unprotected	people,	vessels,	

vehicles	or	structures	and	shall	avoid	endangerment	of	life	and property	of

others.

5. A	successful	radio	equipment	ground-range	check in accordance with

manufacturer’s	recommendations	will	be	completed	before	the	first	flight	of	a	

new	or	repaired	model	aircraft.

6. SUASs	must	use	the	radio	control frequencies currently allowed	by	the	

Federal	Communications	Commission	(FCC).

7. SUASs	will	not	knowingly	operate	within	three	(3)	miles	of	any	pre--- existing flying site without a	frequency---management	agreement.

8. Excluding	takeoff	and	landing,	no	SUASs	may	be	flown	outdoors	closer	than	

25	feet	to	any	individual,	except	for	the	PIC	and	the	VisualObserver	(VO)	

located	at	the	takeoff site.

9. Under	 no	 circumstances	 may	 a	 pilot	 or	 other	 person	 touch	 a	SUAS	 in	

flight	while	 it	 is	 still	 under	 power,	 except	to	 divert	 it	from	 striking	 an	

individual.

10. The	PIC	of	the	SUAS	shall:

a. Maintain	control	during	the	entire	flight,	maintaining	visual	contact	

without	enhancement	other	than	by	corrective	lenses	prescribed	for	

the pilot.

b. Fly	using	the	assistance	of	a	camera	or First	Person View(FPV) only	in	

accordance	with	the	procedures	outlined	in	AMA	Document	#550.

c. Fly	using	the	assistance	of	autopilot	or	stabilization	system	only	in	

accordance	with	the	procedures	outlined	in	AMA	Document	#560.

11. The	flying	area	must	be	clear	of	all	utility	wires	or	poles	and	an	SUAV	will	not be
6

flown	closer	than 50	feet	to any	above-ground electric utility lines.

12. The	flying	area	must	be	clear	before	the	engine	is	started,	except	for	PIC	and	the

VO.

B.	 In	addition	to	the	above	rules	outlined	by	the	AMA	National	Model	Aircraft	

Safety	Code	and	in	an	effort	to	enhance	the	safety	offered	by	the	already	safe	

operations	mentioned	above,	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	

Systems	also	agrees	to	be	bound by	the	following	limitations	and	conditions:

1. Operations	authorized	by	this	petition	for	exemption	are	limited	to	the	

following	aircraft	described	in	the	operating	documents,	which	is	the	DJI	

Inspire	1	Unmanned	Aircraft	System,	a	quadrotor	aircraft	with	a	maximum	

takeoff	weight	of	less	than	7	pounds.	Proposed	operations	of	any	other	

aircraft	will	require	a	new	petition	or	a	petition	to	amend	this	grant.

2. UAS	operations	under	this	petition	are	limited	to	aerial	photography	and	

videography	services	will	be	offered	to	homeowners,	realtors,	builders,	

contractors,	and/or	inspectors	for	use	in,	but	not	limited	to,	real	estate	

marketing,	safer	inspections	of	home	and	building	exteriors	and	closed-set	

filming.

3. The	UAS will	not	be	flown	at	an	indicated	airspeed	exceeding	42	knots	(22	

m/s).

4. The	UAS will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	

ground	level	(AGL),	as	indicated	by	the	procedures	specified	in	the	

operating	documents.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL.

5. The	UAS will	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	

times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	

device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA-issued	

airman	medical	certificate.

6. All	operations	will	utilize	a	VO.	The	VO	will	be	used	to	satisfy	the	VLOS	

requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	

PIC	will	be	able	to	communicate	verbally	at	all	times.	Electronic	messaging	or	

texting	will	not	be	permitted	during	flight	operations.	The	PIC	will	be	

designated	before	the	flight	and	cannot	transfer	his	or	her	designation	for	the	

duration	of	the flight.

7. The	VO	will	not	perform	any	other	duties	beyond	assisting	the	PIC	with	

seeing	and	avoiding	other	air	traffic	and	other	ground	based	

obstacles/obstructions	and	is	not	permitted	to	operate	the	camera	or	other	

instruments.
7

8. The	operating	documents	will	be	accessible	during	UAS	operations	and	made	

available	to	the	Administrator	upon	request.	The	operator	will	follow	the	

procedures	as	outlined	in	its	operating	documents.	The	operator	may	update	

or	revise	its	operating	documents.	It	is	the	responsibility	of	Chop	Shop	

Pictures,	LLC	dba	Raptor	Aerial	Systems	to	track	such	revisions	and	present	

updated	and	revised	documents	to	the	Administrator	upon	request.	Chop	

Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	will	also	present	updated	and	

revised	documents	if	it	petitions	for	extension	or	amendment.	If	Chop	Shop	

Pictures,	LLC	dba	Raptor	Aerial	Systems	determines	that	any	update	or	

revision	would	affect	the	basis	upon	which	the	FAA	granted	this	exemption,	

then	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	will	petition	for	

amendment	to	their	exemption.	The	FAA’s	UAS	Integration	Office	(AFS-80)	

will be	contacted if questions arise regarding	updates	or	revisions	to	the	

operating	documents.

9. Prior	to	each	flight	the	PIC	will	inspect	the	UAS	to	ensure	it	is	in	a	condition	

for	safe	flight.	If	the	inspection	reveals	a	condition	that	affects	the	safe	

operation	of	the	UAS,	the	aircraft	is	prohibited	from	operating	until	the	

necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	

condition	for	safe	flight.	The	Ground	Control	Station	will	be	included	in	the	

preflight	inspection.	All	maintenance	and	alterations	will	be	properly	

documented	in	the	aircraft records.

10. Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	

operation	or	flight	characteristics,	e.g.	replacement	of	a	flight	critical	

component,	must	undergo	a	functional	test	flight	in	accordance	with	the	

operating	documents.	The	PIC	who	conducts	the	functional	test	flight	will	

make	an	entry	in	the	UAS	aircraft	records	of	the	flight.	The	requirements	and	

procedures	for	a	functional	test	flight	and	aircraft	record	entry	will	be	added	

to	the	operating	documents.

11. The	preflight	inspection	section	in	the	operating	documents	will	be	

amended	to	include	the	following	requirement:	The	preflight	inspection	will	

account	for	all	discrepancies,	i.e.	inoperable	components,	items,	or	

equipment,	not	covered	in	the	relevant	preflight	inspection	sections	of	the	

operating	documents.

12. The	operator	will	follow	the	manufacturer’s	UAS	aircraft/component,	

maintenance,	overhaul,	replacement,	inspection,	and	life	limit	requirements,	

with	particular	attention	to	flight	critical	components	that	may	not	be	

addressed	in	the	manufacturer’s	manuals.

13. The	operator	will	carry	out	their	maintenance,	inspections,	and	record-
8

keeping	requirements,	in	accordance	with	the	operating documents.

Maintenance,	inspection,	and	alterations	will	be noted	in	the	aircraft	logbook,

including	total	flight	hours,	description	of	work	accomplished,	and	the	signature

of	the	authorized	UAS	technician	returning	the	UAS	to	service.

14. Each	UAS	operated	will	comply	with	all	manufacturer	Safety Bulletins.

15. An	authorized	person	will	make	a	record	entry	in	the	aircraft	record	of	the	

corrective	action	taken	against	discrepancies	discovered	between	

inspections.

16. Qualification	for	the	Pilot	in	Command

a. Certifications:	A Pilot	in	Command	(PIC)	possessing	at	least	a	private	pilot	

certificate	and	at	least	a	third-class	medical	certificate	will	conduct	

Operations.

b. Logged	Hours:	 Prior	to	 operations	the	 PIC	 will	 have	 accumulated	 and

logged	20	flights	or	log	20	hours	of	flight	time	(the	greater	of	the	two)	

with	the Inspire	1.

c. Currency:	The	PIC	will	have	accomplished,	during	dedicated	training

sessions, 3	take-offs and landings in	the	preceding 90days	(for	currency

purposes).

d. Flight Training:

i. Successfully	learn	and	demonstrate	all	flight	maneuvers	on	

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

ii. Study	and	be	familiar	with	all	sections of	the	“Inspire	1	User	

Manual”.

iii. Study	and	be	familiar	with	all	sections	of	the	“Inspire	1	Safety	

Guidelines”.	(Attachment:	

“Inspire_1_Safety_Guidelines_en.pdf”	document).

iv. Completed	DartDrones,	LLC	training	courses	Drone	Industry	101,	

Basic	Training	and	Advanced	Missions.

e. Emergency	and	Evasive	Maneuvers:	The	PIC	will	have	demonstrated	the	

ability	to	safely	operate	the	Inspire	1	in	a	manner	consistent	with	how	it	

will	be	operated	in	for	actual	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	

Systems	operations,	including	evasive	and emergency maneuvers	and	

maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	

structures.	The	logged	hours	referenced	above	will	document	this.
9

17. UAS	operations	will	not	be	conducted	during	night,	as	defined	in	14	CFR§1.1.	

All	operations	will	be	conducted	under	visual	meteorological	conditions	

(VMC).	Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized.

18. The	UAS	will	not	operate	within	5	nautical	miles	of	an	airport	reference	

point as	denoted on	a	current	FAA-published aeronautical chart	unless a	

letter	of	agreement	with	that	airport’s	management	is	obtained,	and	the	

operation	is	conducted	in	accordance	with	a	NOTAM.	The	letter	of	

agreement	with	the	airport	management	will	be	made	available	to	the	

Administrator	upon	request.

19. The	UAS	will	not	be operated	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.

20. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	return	to	

a	predetermined location	within	the	private	or	controlled-access property	

and	land	or	be	recovered	in	accordance	with	the	operating	documents.

21. The	PIC	will	abort	the	flight	in	the	event	of	unpredicted	obstaclesor	

emergencies	in	accordance	with	the	operating	documents.

22. The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	

forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal	

cruising	speed	to	the	intended	landing	point	and	land	the	UA	with	30%	

battery	power	remaining	in	accordance	with	the	operating documents.

23. The	operator	will	obtain	an	Air	Traffic	Organization	(ATO)	issued	

Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any	

operations	under	this	petition	for exemption.

24. All	aircraft	operated	in	accordance	with	this	petition	will	be	identified by	

serial	number,	registered	in	accordance	with	14	CFR	part	47,	and	have	

identification	(N-Number)	markings	in	accordance	with	14	CFR	part	45,	

Subpart	C.	Markings	will	be	as	large	aspracticable.

25. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	

operation	and	control	of	the	UA	will	comply	with	the Federal	

Communications	Commission	(FCC)	or	other	appropriate	government	

oversight	agency	requirements.

26. The	documents	required	under	14	CFR	§§	91.9	and	91.203	will	be	available	

to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time	the	aircraft	is	

operating.	These	documents	will	be	made	available	to	the	Administrator	or	

any	law	enforcement	official	upon	request.
10

27. The	UAS	will	remain	clear	and	yield	the	right	of	way	to	all other	aviation	

operations	and	activities	at	all	times.

28. The	UAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or	

vehicle.

29. Flight	operations	will	be	conducted	at	least	500	feet	from	all	

nonparticipating	persons	(persons	other	than	the	PIC	or	VO),vessels,	

vehicles,	and	structures unless:

a. Barriers	or	structures	are	present	that	sufficiently	protect	

nonparticipating	persons	from	debris	in	the	event	of	an	accident.	The	

operator	will	ensure	that	nonparticipating	persons	remain	under	such	

protection.	If	a	situation	arises	where	nonparticipating	persons	leave	such	

protection	and	are	within	500	feet	of	the	UAS,	flight	operations	will	cease	

immediately and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the	

land	owner/controller	has	granted	permission	and	the	PIC	has	made	a	

safety	assessment	of	the	risk	of	operating	closer	to	those	objects	and;

c. Operations	near	the	PIC	or	VO	do	not	present	an	undue	hazard	tothe	PIC	

or	VO	per	§	91.119(a).

30. All	operations	will	be	conducted over private or	controlled-access property	

with	permission	from	the	property	owner/controller	or	authorized	

representative.	Permission	from	property	owner/controller	or	authorized	

representative	will	be	obtained	prior	to	the	beginning	of	every flight.

31. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	

vertical	boundaries	of	the	operational	area	as	defined	by	the	applicable	

COA	will be	reported	to	the	FAA’s	UAS	Integration	Office	(AFS-80) within

24	hours.	Accidents	must	be	reported	to	the	National	Transportation	

Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site:	

www.ntsb.gov.

The	operation	of	SUASs,	weighing	less	than	7	lbs.,	conducted	in	the	strict	conditions	

as	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	

exemptions	requested	herein,	including	exempting	the	applicant	from	the	

requirements	of	Part	21	and	allowing	commercial	operations.

These	lightweight	aircraft	operate	at	slow	speeds,	close to	the	ground,	and	in	a	

tightly	controlled	environment.	As	a	result,	they	offer	a	much	safer	way	to	capture	

aerial	photography	and	videography.	Furthermore,	the	proposed	operations	
11

represent	a	safety	enhancement	to	the	already	safe	operations	that	have	been	

granted	by	the	FAA	for	the	establishment	of	the	AMA	National	Model	Aircraft	Safety	

Code.

Preflight	Action	Plan

The PIC will follow a comprehensive	pre-flight checklist to ensure that the SUAS is in	

a	condition	for	safe	flight.	This	plan	will	be	improved	as	needed	in	order	to	ensure	all	

known	safety	precautions	and/or	safety	precautions	suggested	by	the	manufacturer	

are	being	accounted	for.

Pre---flight	Inspection

1. Check	that	the	remote	control,	Inspire	1	battery	and	

iPad/smartphone	are	all	fully	charged.

2. Verify	that	the	Inspire	1	battery	is	not	swollen	or	damaged	in	any	way.	

Clean	the	contact	needles	and	pads	if necessary.

3. Turn	the	motor	shafts	with	fingers	and	verify	they	are	smooth	

without	excessive	play	or binding.

4. Verify	that	the	propellers	are	mounted	correctly.	Propellers	with	a	black	

top	should	be	mounted	on	the	mount	shafts	that	have	a	black	dot.	

Propellers	with	a	silver	top	should	be	mounted	on	the	mount	shafts	that	

have	a	silver	dot.	Each	propeller	should	spin	all	the	way	down	onto	the	

motor	shaft.

5. Run	finger	along	the	edge	of	edge	blade	to	check	for	any	roughedges.

6. Flex	both	sides	of	the	propeller	blades	to	check	for	hairline	cracks	where	

the	blades	connect	in	the	center	of	thepropeller.

7. Verify	that	the	landing	gear	is	secure	(notcracked/broken/loose).

8. Verify	that	the	compass	and	compass	cable	is	firmly	attached	to	the	

landing gear.

9. Verify that	the Micro---SD card	has been	inserted	and	formatted.

10. Verify	that	the	damping	absorbers	are	not	broken	and/or	worn.

11. Verify that	the anti---drop	pins are	in place	and	locked.

12. Attach	the	gimbal	to	the	Inspire	1.

13. Verify	that	the	camera	is	secure	and	clean.	Inspect	the	camera	ribbon	

cables	for	tears	and/or	signs	of wear.

14. Verify	that	the	iPad/smartphone	GPS	is	enabled.

15. Set	the	iPad/smartphone	to	do-not-disturb	mode	to	prevent	distractions	

while	flying.

16. Set	the	iPad/smartphone	to	forget	any	Wi-Fi networks	in	range	in	

order to	prevent the	Wi-Fi	connection	from	changing	mid---flight.

17. Verify	that	the	iPad/smartphone	audio	is	on	to	ensure	the	low	

battery	warning	and	other	alarms	can	be	heard.

Power Up

18. Verify	that	S1	and	S2	are	in	the	top	position	on	the	remote	control.

19. Power	on	the	equipment	in	the	following	sequential order:
12

a. Remote	Control	(2	beeps	to	indicate	it’s	in	FCC	mode)

b. Insert	and	start	the	Inspire	1	battery.

c. Connect	and	iPad/smartphone

20. Watch	the	Inspire	1	LED	startup	sequence	for	abnormal	indications.	The	

rear	LEDs	should blink green	for	at	least 10-15	seconds	to	indicate that	it	

locked	onto	6+	satellites	and	has	marked	the	home	point	(for	use	by	the	

failsafe feature).

21. Calibrate	the	Inspire	1’s	compass.

22. Place	the	Inspire	1	on	an	open,	flat	ground	with	the	battery	indicators	

facing	towards	the	PIC	at	least	10	feet away.

DJI	Go	Application

23. Launch	the	“DJI	Go”	application	on	the	smartphone.

a. Verify	the	number	of	satellites	is	6+.

b. Verify the	Wi-Fi signal	strength.

c. Verify	that	the	Inspire	1	and	remote	control	batteries	are	

reporting	a	full charge.

d. Verify	that	both	the	PIC’s	and	Inspire	1’s	location	is	the	same	

before	taking	off	to	ensure	the	home	point	has	been	accurately	

marked.

e. Verify	the	location	of	the	Inspire	1	in	the	“Flight	Radar”.	If	it’s	

not	in	the	correct	position/direction	and/or	shows	a distance	

of	“N/A”,	it	did	not	mark	the	home	point.

Ready	to Fly

24. Verify	that	the	remote	control	antenna	is	perpendicular	to	the	ground	

(pointing skyward).

25. Verify	that	the	rear	LEDs	are	still	slowly	blinking	green	and	still	

connected	to	6+ satellites.

26. Start	the	Inspire	1	motors	using	the	CSC	command	on	the	remote control.

27. Verify	that	the	motors	are	functioning	normally,	are	not	making	any	

unusual	noises,	and	are	all	spinning	at	the	same	speed.

28. Verify	that	the	area	is	still	clear	of	obstructions,	people,	power	lines,etc.

29. Take	off	and hover	at	about	6-8	feet	above	the	takeoff	point	to	verify that	
13

the	Inspire	1	has	a	solid	GPS	lock.	If	any	abnormalities	are	noticed	

(drifting,	flying	in	circles,	etc.),	land	immediately	and	repeat	the	“Preflight	Inspection”	and	“Power	Up” sequences.

30. Verify	that	the	Inspire	1	holds	a	steady	position	while	yawing	360	

degrees.

31. Verify	that	the	Inspire	1	responds	appropriately	to	all	controls	– yaw	

left/right,	pitch	forward/backward,	roll	left/right,	and	throttleup/down.

Preventative	Maintenance

A	comprehensive	preventative	maintenance	plan	will	be	followed	in	order	to	ensure	

the	SUAS’s	software	is	up	to	date,	the	batteries	are	in	good health,	and the	aircraft

itself	is	always	ready	for	safe	flight.

(Attachment:	“Inspire_1_Maintenance_ManualV1.0_en.pdf”	document).

Public	Interest

Granting	this	exemption	would	benefit	the	public	as	a	whole.	SUASs	offer	a	

strong	equivalent	level	of	safety,	a	reduction	in	environmental	impacts,	and	are	

free	from	the	harmful	emissions	associated	with	the	manned	aircraft	that	are	

currently	used	for	aerial	photography	and	videography.	Due	to	the	size	of	the	

SUAS	and	the	tightly	controlled	and	limited	airspace	in	which	the	SUAS	will	

operate,	approval	of	this	application	presents	no	risk	to	the	public.	

Furthermore,	the	public	will	be	able	to	legally	acquire	aerial	photography	and	

videography	to	help	in,	but	not	limited	to,	advertising	homes	for	sale,	

advertising	uninhabited	home	lots,	use	of	photos	and	video	as	an	aid	when	

researching	homes	for	sale	on	the	market,	or	safely	accessing	high	and/or	

awkward	areas	of	a	home’s	exterior	to	assess	damage	that	needs	to	be	repaired.

Privacy

Since	the	areas	being	photographed	or	filmed	will	be	on	private	property,	accessed	

only	after	given	written	and/or	oral	consent	by	the	property	owner(s),	and	clear	of	

all	people,	except	for	the	PIC	and	the	PIC's	helper(s),	approval	of	this	application	

presents	no	risk	to	the	public privacy.

National Security

Due	to	the	size	of	the	SUAS	and	the	tightly	controlled	and	limited	airspace	in	which	

the	SUAS	will	operate,	approval	of	this	application	presents	no	risk	to	national	

security.

Requested	Exemptions

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	requests	exemption	from	the	

following	 regulations	 since	it’s	not	possible	to	fully	 comply with	them,	 and	 since	

attempting	to	follow	them	for	the	purposes	of	operating	a	SUAS	would	be	a	burden:
14

Airworthiness	Certificates

14	CFR,	Subpart H

Part	21	covers	certification	procedures	for	products	and	parts.	Subpart	H	

specifies	requirements	for	Airworthiness	Certificates	for	various	aircraft	

types.	Small	unmanned	aircraft	systems	are	not	specifically	called	out	and	

addressed	in	these	rules.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	

will,	in	lieu	of	airworthiness	certification	by	aforementioned	rule,	if	

exemption	is	granted,	ensure	that	the	Inspire	1	system	is	in	compliance	with	

its	operating	documents	as	described	herein.	The	PIC	will	assure	that	all	

Preflight	Checks	are	completed	and	documented	and	there	is	full	compliance	

with	all	manufacturer’s	operation	and	maintenance	documents.	Due	to	

consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated	

with	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems’	proposed	Inspire	1	

we	believe	it	will	not	create	a	hazard	to	users	of	the	National	Airspace	System	

(NAS)	or	the	public.	Therefore,	a	request	is	made	for	exemption	from	14	CFR	

part	21,	and	any	associated	noise	certification	and	testing	requirements	of	

part	36.

Private	pilot	privileges	and	limitations:	Pilot	in	command

14	CFR	61.113 (a)

Under	current	regulations,	civil	operations	for	compensation	or	hire	

require	a	PIC	holding	a	commercial	pilot	certificate	per	14	CFR	Part	61.	

Based	on	the	Private	Pilot	limitations	in	accordance	with	pertinent	parts	of	

14 CFR	§61.113(a),	a	pilot	holding	a	Private	Pilot	certificate	cannot	act	as	a	

PIC	of	an	aircraft	for	compensation	or	hire.	However,	in	Grant	of	Exemption	

No.	11062	to	Astraeus	Aerial	(Astraeus),	the	FAA	determined	that	a	PIC	

with	a	private	pilot	certificate	operating	the	Astraeus	UAS	would	not	

adversely	affect	operations	in	the	NAS	or	present	a	hazard	to	persons	or	

property	on	the	ground.

Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	operation	will	not	differ	

significantly	from	the	situation	described	in	Grant	of	Exemption	No.	11062	

(Astraeus	Aerial).	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	Systems	plans	

to	operate	over	private	property	with	controlled	access	in	the	NAS.	With	the	

similar	nature	of	the	proposed	operating	environment	to	that	of	Astraeus,	

the	parallel	nature	of	Private	Pilot	aeronautical	knowledge	requirements	to	

those	of	commercial	requirements	[ref:	Exemption	No.	11062],	and	the	

airmanship	skills	necessary	to	operate	the	UAS,	Chop	Shop	Pictures,	LLC	dba	

Raptor	Aerial	Systems	believes	that	the	additional	airmanship	experience	of	

a	commercially	certificated	pilot	would	not	correlate	to	the	airmanship	skills	

necessary	for	the	specific	proposed	operations.	Therefore,	Chop	Shop	

Pictures,	LLC	dba	Raptor	Aerial	Systems	PICs	will	hold	a	minimum	of	a	
15

private	pilot	certificate	and a	third-class	airman medical certificate.

Airworthiness	required	for	operation

14	CFR 91.7(a)

If	the	exemption	from	14	CFR	21,	Subpart	H	(item	1	above)	is	granted,	no	

airworthiness	certificate	will	be	required.	On	this	basis,	exemption	from 14	

CFR	91.7	(a)	is	requested,	presuming	that	airworthy	condition	by	definition	

in	the	rule	means	having	an	airworthiness	certificate.	Chop	Shop	Pictures,	

LLC	dba	Raptor	Aerial	Systems	will,	in	lieu	of	airworthiness	certification	by	

14	CFR	21,	ensure	that	the	Inspire	1	system	is	in	compliance	with	its	

operating	documents	as	described	herein.	The	PIC	will	assure	that	all	

Preflight	Checks	are	completed	and	documented	and	execute	full	compliance	

with	all	manufacturer’s	operation	and	maintenance	documents.

Flight	crewmember	at	stations

14	CFR 91.105

This	part	requires	certain	actions	by	onboard	crewmembers.	Since	the	

Inspire	1	is	unmanned,	an	exemption	from	this	rule	is requested.

Minimum	Safe Altitudes

14	CFR 91.119(c)

This	regulation	requires	all	operation	to	remain	no	closer	than	500	feet	

from	persons,	vessels,	vehicles,	and	structures.	Chop	Shop	Pictures,	LLC	dba	

Raptor	Aerial	Systems	requires	relief	from	§	91.119(c)	is	because	all	

operations	will	be	conducted	below	400	feet	AGL	and	may	be	operated	

closer	than	500	feet	from	persons,	vessels,	vehicles,	and	structures	as	

described above.

Prior	to	conducting	UAS	specific	operations,	all	persons	not	essential	to	flight	

operations	(nonparticipating	persons)	must	remain	at	appropriate	distances.	

In	open	areas,	the	UAS	will	remain	500	feet	from	all	persons	other	than	

essential	flight	personnel	(i.e.	the	PIC	and	VO).	If	barriers	or	structures	are	

present	that	can	sufficiently	protect	nonparticipating	persons	from	debris	in	

the	event	of	an	accident	then	the	UAS	may	operate	closer	than	500	feet	to	

persons	afforded	such	protection.	Chop	Shop	Pictures,	LLC	dba	Raptor	Aerial	

Systems	will	ensure	that	nonparticipating	persons	remain	under	such	

protection.	If	a	situation	arises	where	nonparticipating	persons	leave such	

protection	and	are	within	500	feet	of	the	UAS,	flight	operations	must	cease	

immediately.	The	primary	concern,	when	considering	how	to	immediately	

cease	operations,	is	the	safety	of	those	nonparticipating	persons.	Operations	

may	be	conducted	closer	than	500	feet	to	vessels,	vehicles	and	structures	

when	the	land	owner/controller	grants	such	permission	and	the	PIC	makes	a	
16

safety	assessment	of	the	risk	of	operating	closer	to	those	objects.

Altimeter	settings

14	CFR 91.121

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.	The	operator	will	

achieve	an	equivalent	level	of	safety	by	confirming	the	altitude	of	the	launch	

site	shown	on	the	GPS	altitude	indicator	before flight.

Fuel	Requirements	for	Flight	in	VFR	Conditions

14	CFR	91.151 (a)

This	regulation	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.”

Similar	UAS-specific relief	has	been	granted	an	Exemption Nos. 8811, 10808,

and	 10673	 for	 daytime,	 Visual	 Flight	 Rules	 (VFR)	 conditions.	 Chop	 Shop	

Pictures,	LLC	dba	Raptor	Aerial	Systems	UAS	provides	low	battery	warnings	

at	30%	capacity	that	indicate	the	PIC	must	command	the	UAS’	return	to	the	

launch	 point	 when	 low	 battery	 capacity	 voltage	 is	 reached.	 The	 UAS	 also	

provides	 critical	 low	 battery	 warnings	 at	 15%	 battery	 capacity	 indicating	

that	 the	 UA	 will	 begin	 to	 descend	 and	 land	 automatically.	 These	 factors	

provide	 an	 equivalent	 level of	 safety	 by	 prohibiting	 the	 from	 beginning	 a	

flight	 unless	 (considering	 wind	 and	 forecast	 weather	 conditions)	 there	 is	

enough	power	to	fly	at	normal	cruising	speed	to	the	intended	landing	point	

and	land	the	UA	with	30%	battery	power	remaining.

Maintenance	Inspections

14	CFR	91.405	(a);	14	CFR	91.407	(a)(1);	14	CFR	91.409	(a)(1)	and	(2);	14	

CFR	91.417	(a)	and (b)

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	sections	and	Part	43	apply	only	to	aircraft with	an	
17

airworthiness	certificate,	these	sections	will	not	apply.	Maintenance	will	be	

accomplished	by	the	operator	pursuant	to	the	aforementioned	Inspire	1	user	

manual	and	guide.	An	equivalent	level	of	safety	will	be	achieved	because	

these	small	SUASs	are very	limited	in	size,	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. As outlined in the aforementioned Pre-Flight	Action	

Plan,	the	operator	will	ensure	that	the	SUAS	is	in	working	order	prior	to	

initiating	flight	and	perform	maintenance	as	required.	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.

In	accordance	with	14	CFR	Part	11,	the	following	summary	is	provided	for	

publication	in	the	FederalRegister:

The	applicant	seeks	an	exemption	from	the	following	rules:	14	CFR Part	21,	Subpart	

H;	14	CFR	61.113	(a);	14	CFR	91.7(a);	14	CFR	91.105;	14	CFR	91.119(a);	14 CFR

91.121;	14	CFR	91.151;	14	CFR	91.405	(a);	14	CFR	91.407	(a)(1);	14	CFR 91.409

(a)(1)	and	(2);	14	CFR	91.417	(a)	and	(b)	to	commercially	operate	small	unmanned	

aircraft	systems	(55	lbs.	or	less)	in	order	to	safely	and	legally	capture	aerial	

photography	and	videography	for	use	by	homeowners,	realtors,	builders,	

contractors,	and/or inspectors	and	closed	set	filming.

The	operation	of	SUASs	conducted	in	the	strict	conditions	outlined	above,	will	

provide	an	equivalent	and/or	greater	level	of	safety	supporting	the	grant	of	the	

exemptions	requested	herein,	including	exempting	the	applicant	from	the	

requirements	of	Part	21	and	allowing	commercial	operations.	These	lightweight	

aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	sterile	environment,	and

as a result, are far safer than existing operations conducted with helicopters	

operating	in	close	proximity	to	the	ground,	people,	or	other	buildings	in	the	vicinity.

Given	the	small	size	of	the	SUASs	involved,	the	slow	speed	at	which	they	must	be	

operated	in	order	to	capture	photos	and	videos,	and	the	restricted	environment	

within	which	they	will	operate,	the	Inspire	1	demonstrates	that	it	can	be	operated	

within	an	equivalent	level	of	safety	in	which	Congress	envisioned	that	the	FAA	must,	

by	exemption,	allow	commercial	operations	of	SUASs	to	commence	immediately.

Also,	due	to	the	size	of	the	SUASs	and	the	restricted	areas	in	which	the	relevant	

SUASs	will	operate,	approval	of	this	application	presents	no	threat	to	national	

security.	Given	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	

contained	in	the	Federal	Aviation	Act,	the	strong	equivalent	level	of	safety	

surrounding	the	proposed	operations,	the	significant	public	benefit	– including	

enhanced	safety,	reduction	in	environmental	impacts,	no	emissions,	ability	to	legally	

obtain	aerial	photography	and	videography	services	– the	grant	of	the	requested	

exemptions	is	in	the	public	interest.	Accordingly,	Chop	Shop	Pictures,	LLC	dba	Raptor	

Aerial	Systems	respectfully	requests	that	the	FAA	grant	the	requested	exemption	

without delay.
18

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	– size,	

weight,	speed,	operating	capability,	proximity	to	airports	and	populated	areas,	

operation	within	the	visual	line	of	sight,	public	safety,	and	national	security	–

provide	more	than	adequate	justification	to	grant	Chop	Shop	Pictures,	LLC	dba	

Raptor	Aerial	Systems	the	requested	exemption,	allowing	for	commercial	

operations	as	described	herewith.

Summary	for	Publication	in	Federal Register

Petition	for	Exemption

Docket	No.: FAA-2015-XXXX

Petitioner:	Chop	Shop	Pictures,	LLC	

dba	Raptor	Aerial	Systems

Sections	of	14 CFR

Description	of	Relief	Sought:	The	petitioner	is	seeking	an	exemption	to	

utilize	an	unmanned	aircraft	system	(UAS)	to	accomplish	aerial	photography	

and	videography	services	to	homeowners,	realtors,	builders,	contractors,	

and/or	inspectors	for	use	in,	but	not	limited	to,	real	estate	marketing	and	

safer	inspections	of	home	and	building exteriors.

Sincerely,

/s/	John	Robinette

John	Robinette,	Owner,	Chop	Shop	Pictures,	LLC

dba	Raptor	Aerial	Systems	

Enclosures (3)
19