July 28, 2015

William Paul Richard, Director’s Chair Production, LLC

5239 Pembroke Way, San Ramon, CA 94582, 510-409-0655, dcpbayarea@gmail.com

www.directorschairproductions.com

Federal Aviation Administration: 

I, William Richard of Director’s Chair Productions, LLC, the petitioner, am writing 

pursuant to the FAA Modernization and Reform Act of 2012 and the procedures 

contained within 14 C.F.R. 11, to request that as an experienced operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed 

below so that I may operate an unmanned aircraft system (“UAS”) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with 

FAA UAS Regulations & Policies. 

This is a formal request for an exemption from the following Section 333 regulations: 14 

C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 

91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) 

and (2), 14 C.F.R. 91.417(a) and (b). The petitioner intends to operate DJI’s following 

UAS: Phantom 2, Phantom 3, and Inspire 1 precisely within the FAA UAS guidelines as 

well as those which accompany DJI Phantom 2, DJI Inspire 1, and DJI Phantom 3 

Operator’s manuals. Each petitioner’s UAS are equipped with detachable cameras, GPS 

tracking and guidance, and are always transported or stored safely. This proposed 

exemption would allow me operation of unmanned aircraft systems (UAS) for the 

purpose of aerial videography/ photography as a service to the public/ business 

interests. As found in exemption No. 11138 (Trudeau), the FAA recently approved 

similar use of a Phantom 2 UAS. 

All of these devices are equipped with many safety features that, when utilized with 

following the petitioner’s strict safety protocol before each flight, have proven to be a 

reliable, safe, and environmentally friendly way to provide aerial imaging services. The 

petitioner’s UAS fleet all utilize gyro stabilized flight, ground detection (phantom 3 and 

inspire 1), GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning 

home, and voice confirmation of real time flight information. This will act to further safety 

protocols exclusive to lightweight UAS’s specific to video and photography usage as I 

record flight data and other information gained through permitted flight operations to 

share with the FAA through any required FAA reports to assists with future protocol and 

safety regulations. 

The petitioner has been and receives ongoing aeronautics training from our PIC, a 

certified FAA private pilot, Robert Kinsey, (FAA license number undisclosed since social 

security numbers are used in these cases) to ensure all FAA safety protocols are 

administered before, during, and after each flight. 

The petitioner has and will continue to keep current aviation insurance for each UAS to 

protect the public’s interest and property from any accidental damage in the event of a 

collision. 
Specific section or sections of 14 CFR which I seek relief and the reason I seek 

relief: 

14 C.F.R. Part 21: Airworthiness Certificates 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements outlined in Petitioners Operations Manual. Given the size 

and limited operating area associated with the UAS to be utilized by the petitioner, an 

exemption from Part 21 meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than 

conventional aircraft operating with an airworthiness certificate without restrictions and 

conditions proposed. 

14 C.F.R. 45.23: Display of marks: general 

The UAS will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to 

mark certain words or phrases. Further, the two inch lettering is difficult to place on such 

a small aircraft with dimensions smaller than the minimal lettering requirement. 

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command 

The petitioner utilizes our PIC, Robert Kinsey, FAA certified private pilot, for aeronautics 

training and safety. The FAA has previously declared that additional manned airship 

experience of a commercially certified pilot would not correlate to the airmanship skills 

necessary for similarly proposed operations in previously issued exemptions to this 

regulation through Exemption Nos. 11062 and 11138. 

14 C.F.R 91.7: Civil aircraft airworthiness 

Currently, since there is no certificate applicable to the UAS in question, this regulation is 

inapplicable. 

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements 

Requires an aircraft flight manual in the aircraft, however there are no pilots or 

passengers on board this aircraft and given its size, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual with the 

operator. 

14 C.F.R. 91.119(c): Minimum safe altitudes 

The petitioner will ensure that UAS do not operate any higher than 400 feet at ground 

level. The petitioner will not fly over congested areas of pedestrians or wildlife. I will plan 

operations before hand, for proper flight safety, and proper height analysis to maintain 

maximum safety for each flight. 
14 C.F.R. 91.121: Altimeter settings 

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety is 

achieved by setting applicable altitude limits according to the DJI operations manual as 

well as voice recognition from the ground control unit. 

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions 

The UAS that I will fly are powered by electricity, using lithium polymer batteries that 

currently have a flight limit of approximately no more than 20 minutes. Therefore, due to 

the limitations of the batteries, it is currently impossible to comply with part 91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness certificates for the 

mentioned UAS. The petitioner will always fly safely under strict direction from our PIC 

Robert Kinsey, certified FAA private pilot, and the manuals of the DJI Phantom 2, DJI 

Inspire 1, and the DJI Phantom 3. 

14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, 

rebuilding, or alteration,

14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records 

Maintenance inspections may be required and should be granted since they only apply 

to aircraft with an airworthiness certificate. The petitioner will perform preflight 

inspections of the UAS before each flight as outlined in the operating documents. The 

petitioner will also follow manufacturer recommendations from said operating 

documents. 

Public Interest 

Aerial photography and videography as an available service to the public allows for a 

safer, less expensive, and environmentally friendly alternative to manned aircraft and 

helicopters. They are expensive, create lots of noise, and are much more threatening 

due to size and combustible fuel. 

The petitioner would eagerly offer my services upon request and with proper 

coordination to any official search and rescue or emergency services organization to 

benefit the public. 

Also as mentioned in the Trudeau exemption, exemption No.11138: 

““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 

more, are operated by an onboard pilot and may carry other onboard crewmembers, as 

well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The 

pilot and crew will be remotely located from the aircraft. The limited weight reduces the 

potential for harm to persons or damage to property in the event of an incident or 
accident. The risk of an onboard pilot and crew during an incident or accident is 

eliminated with the use of a [sUAS] for the proposed operation.” 

Summary

The petitioner, William Richard of Director’s Chair Productions, LLC, is seeking 

exemption from the following rules: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 

91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) 

and (2), 14 C.F.R. 91.417(a) and (b) 

With the exemptions of the mentioned rules the petitioner will be seeking to make my 

aerial photography/videography services available to the public. Alternatively the public 

had saut to use helicopters and aircraft to achieve what the petitioner can offer in a 

safer, more cost efficient manner. The UAS operated by the petitioner are not using 

combustible fuel, always fly at safe heights, and strictly following the usage 

recommendations from DJI as well as all FAA regulations. 

These include but are not limited to: 

 ● Flying the following UAS Safely:○ DJI Inspire 1 ○ DJI Phantom 2 ○ DJI 

Phantom 3 

 ● Flying below 400 feet 

 ● Proper visual inspection of UAS before flights 

 ● Keeping mentioned UAS in visual sight at all times when in operation 

 ● Using an observer to assist if needed 

 ● Remain well clear of and do not interfere with manned aircraft operations, and 

avoid other aircraft and obstacles at all times 

 ● Not intentionally fly over unprotected persons or moving vehicles 

 ● Contact the airport or control tower before flying within 5 miles of an airport 

 ● Not flying in adverse weather conditions such as high winds or reduced 

visibility 

 ● Not flying under the influence of alcohol or drugs 

 ● Ensure the operating environment is safe 

 ● Not flying over sensitive infrastructure or property such as power stations, 

water treatment facilities, correctional facilities, etc. 

 ● Check and follow all local laws and ordinances before flying over private 

property 

 ● Do not conduct surveillance or photograph persons in areas where there is an 

expectation of privacy without the individual's permission. 

Sincerely, 

William Paul Richard, Director’s Chair Production, LLC

5239 Pembroke Way, San Ramon, CA 94582, 510-409-0655, dcpbayarea@gmail.com

www.directorschairproductions.com