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Chad Medford Video Production 

1111 Tiney Rd 

Ellenboro, NC 28040 

828.429.5148 

chadandmyra@gmail.com 

July 29, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

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RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

CFR 91.7(a};91.119(c); 91.407(a)(1);9])iQ9{a)(1) and {2); 91.417(a)&(b); C.F.R. 61.113(a(&(b); C.F.R. 

61.133 (a); C.F.R. 91.405 (a). . . 

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To whom it may concern, · .· 

Enclosed please find an exemptic•r application filed on behalf of Chad Medford Video Production. (CMV) 

under Section 333 ofthe FAA Mociernization and Reform Act of 2012 and 14 C.F.R Part 11 to allow 

commercial operations of unmanne-d aircraft for aerial photography and videography for the real estate, 

construction, and utilities Industries for commercial .use, so long as such operations are conducted within 

and under the conditions outlined lierein or as established by the FAA in an exemption granted under 

either Section 333 or Section 

It is the request of the petitioner for exemptions listed above in order to legally and safely operate the DJI 

Phantom 3 Vision Plus UAS, DJI 5900 UAS and a 3D Robotics Solo in the National Airspace System. 

CEM is a leading production company in Western North Carolina with an extensive background in 

television production and videography. Ct:M proposes to use small, lightweight, UAVs and proprietary 

cloud-based software. 2 
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As discussed beiOW1 CEMs operatk,ns under the exemption will be subject to strict operating 

requirements and conditions to e~sure at least an. eq!~illaient level of safety to currently authorized 

operations using manned aircraft and under C<lndition.; as may be modified by the FAA <lS required by 

Section 333. 

It is the petitioners position that the oper<1tions for which exemption is requested are safer and more 

cost effective than using man'ned aircraft and for those reasons are in the Public Interest; and would be 

of benefit in identifying areas of operation that may need additional oversight as well as raising public 

awareness and interest in this rapidly browing facet of aviation. 

Because these small UASs will be used :n lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary manned aircraft/ CEM respectfully submits that the FAA can have confidence that 

the operations will achieve at least an equivalent level or greater level of safety. Approval of this 

exemption would thereby enhance safety and fulfil~ 333~c) of the Reform Act to "establish requirements 

for the safe operation of such aircraft systems in the n<Hional airspace system." 

Section 333's Legal Standard 

Grant of this exemption application for use of the above named UAV's for purposes of obtaining and 

recording video will advance the Congressional mandate in Section 333 of the Reform Act to accelerate 

the introduction of UASs into the national airspace ·system «'NAS") if such integration can be 

accomplished safely. The statutory provision direc:tsthe Secretary of Transportation to consider whether 

certain UASs may operate safely in the NAS befor~ completion of the rulemaking required under Sections 

the Secretary of Transportation to consider whetn:er certain UASs may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. In doing S01 the Secretary is 

required to 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; 

f!l The UAS's size/ weight speed1 and operational capability; 

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

Ill Operation of the UAS within vi sua! llne of sight of the operator 

If the Secretary determines that ~..:d1 vr~hicles "may operate safely in the national airspace system, the 

Secretary shall establish requirer :.~nt.s for the safe operation of such aircraft in the national airspace 

system. (333 emphasis added) . 

The Federal Aviation Act expressly grants the FAA the- 1uthor.w to issue exemptions. This statutory, by its 

terms, includes exempting civil ain:;·aft, as the term iS:.defined under 40101 of the Act, from the 

requirement that all civil aircraft rnu5-t have~ i!urr~nt airworthiness certificate and those regulation 

requiring commercial pilots to operate aircraft in commercial service. 

Reform Act 333(a)(1) · 

Applicant submits that this provision places a duty on the Administrator to not only process applications 

for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein 

require modification in order to allow ~pproval, to supply conditions for the.safe operation of the l,IASs. 

CEM requests to consult with the FAA staff to address any issues or concerns "that they believe may 

require such modification. 

The Administrator may grant an exemption from·· a .requirement of a regulation prescribed under . ' . 

. subsection (a) or (b) of this section or any of sections "44702-44716 of this title if the Administrator finds 

the exemption is in the public interes-t. -,, · 

49 U.S.C 440701{f) See also 49 U.S.C44711(a); 49 u.s.c 44704; 14 C.F.R 9-1.203{aJ(1). 

The grant of the requested exemption is in the public· interest given the clear direction in Section 333 of 

the Reform Act; the additional authority In the Federal Aviation Act, as amended; the strong equivalent 

level of safety surrounding the proposed operations; and the significant public benefit arising from the 

use of new technology to provide services that are not practical or safe 4 
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to provide using traditional aircran. Accord.ingly, the applicant respectfully requests that the FAA grant 

the requested exemption without deiay. 

Aircraft and Equivalent of Level of Safety 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations and conditions listed herein. These limitations 

provide for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to operations 

that would be conducted with conventional aircraft. These conditions are drawn from Exemptions 11062 

through 11067, 11080, 11109, 11110, 11136, 11138, 11150 and 11153. 

Additional Issues 

Privacy- All flights will occur over private or controlled access property with the property owner's prior 

c:onsent and knowledge. Operation>· will be where the owners have agreed to all CEM's activities to take 

pface. In addition, members of thoi.· 1-i'~!:-e•al public will be alerted to the operation of UASs at these 

locations. . ., 

In filing this application, Chad Medford Video Production also requests that the FAA combine the grant of 

the Section 333 exemption with a starid-alope CeH;jfi!=~te of.Operation ("COA'') that will allow commercial 

operations of DJI Phantom 3 Vision plusUAS, DJI ~.900-UAS and a 3DRobotics Solo without filing for a COA for 

each flight. Compliance with the ccnditici1ns ag~eed ·hereil' and that may be imposed by the FAA, as set forth in 

prior Section 333 exemptions, provide the sepc.ration needed from other aircraft. Notice to airmen and notice 

to air traffic control can be provided by the "filing of a NOT AM as set forth within the proposed conditions. 5 
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National Security 

Grant of this exemption will not raise any natic~··.<'lf security concerns. Given the size, load carrying 

capacity, speed at which they operate and the fact. that it carries no explosives or any other dangerous 

materials, the DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and a 3D Robotics Solo pose no threat to 

national security. 

Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- size, weight, speed, 

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

and national security- provide more .than adequate justification for the grant ofthe requested 

exemptions allowing commercial operation of applicants UAVs for the purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions 11062 through 11067, 11080, 11109 

through 11112, 11114, 11136, 11138, 11150 and 11153. 

Given that CEM is willing to abide by conditions the FAA has required in issuing recent Section 333 

exemptions, the FAA has a strong basis for prompt consideration and grant of this request. 

Please contact CEM if there are any other questions or concerns. 

Best regards, 

Chad Medford 

owner 

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Exemption Request and Equivalent level of Safety Showings under 

Applicable Rules Subject to, Exemption 

CEM request an exemption from the following regulations as well as any additional regulations that may 

apply to the operations of the DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and a 3D Robotics Solo. 

14 C.F.R. 61.113(a)(b); 61.133{a)~ Private Pilot Privileges and limitations; Pilot in 

Command; Commercial Pilot Pr~vileges and Limitations. 

Section 61.113(a)(b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that 

carries a pilot, passengers and cargo, the DJI Phantom 2 Vision Plus UAS, DJI S900 UAS and 3DRobotics 

Solo are remotely controlled with no passenger.s or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot's license to be the.pilot in command of any aircraft for hire 

and/or compensation. CEM proposes that operator requ!rements should take into account the 

characteristics of these particular UAS's. 

DJI Phantom 2 Vision Plus UAS, DJI 5900 UAS and the 3DRobotics Solo have navigation and control 

systems capable of conducting pre-programmed missions. Flights are pre-programmed with precision 

GPS guidance and, although monitored by the PIC and Observer, do not require human intervention. The 

aircrafts also can operate in guided mode, where the aircraft will fly to a location designated by the 

operators. In the case of an unplanned event, operators can manually intervene and take one of the 

following actions: 

Ill Command the aircraft to return and land attne recovery location 

Ill Command the aircraft to conduct a return to the recovery area. where the pilot will assume control and 

land the aircraft · · · ., · .,., ., · 

111 Manually assume control of the aircraft via the hand controller and return the craft to the recovery area 

in which the operator land its manually 

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Additionally, the automated safety functions and safety enhancing features include the following: 

Ill Auto-pilot detection of lost GPS initiates GPS failsafe mode, in which the aircraft switches to manual 

control in an altitude hold mode. 

rn Low battery power on the aircran: ;~riggers the la,"ding sequence and then the craft will land at the 

current location 

rn If the aircraft detects a lost-link to the ground control station, it will return to the launch site and land. 

lZJ If the aircraft exceeds an altitude of 40Dtl AGL or.go~s more than 2 km from its launch point (except it it 

is in GPS failsafe mode), it will return to the la~mch point, automatically. 

Given these safety features, CEM purposes that operators of the UAS's should not be required to hold a 

commercial pilot certification. Instead, operators should be required to hold only a private pilot 

certification. 

The risks associated with the operatioP of DJI Phantom 3 Vision Plus UAS, DJI S900 UAS and the 

3DRobotics Solo are so diminished from the.level of risk associated with commercial operations 

contemplated by Part 61 with conventional aircraft that allowing operations of the UAS's as set forth 

above meets and/or exceeds the present leveJ.,-,f safety provided under 14 C.F.R. 61.113(a)(b) and does 

not rise to the level of requiring a commercial piiq,t i:o operate the aircraft under 61.133(a). 

Given these conditions and restrictions, an equivalem !•"i!e! of safety will be provided allowing operation 

of the DJI Phantom 3 Vision Plus UAS, DJI 5900 UA3 and the 3DRobotics Solo with a private pilot's 

certificate, under the conditions set forth in the exemption re, quest. The FAA has, granted exemptions to 

conduct similar operations in .Exemptions 11062 through 11067, 11080, 11109, 11110, 11136 and 11138. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. As set forth herein, CEM will never 

operate at higher than 400 feet AGL. It will, however, be operated to avoid congested or populated areas 

that are depicted in yellow on VFR sectional charts. No flight will be taken without the permission of the 

landowner, all affected individuals w.m be aware of and will have signed waives consenting to the flights. 

CEM will ensure that the aircraft will remain at least 500 feet away from non-participants unless they are 

protected from potential hazards by barriers or structures. 

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

This regulation prohibits an in.dividual fro·m 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 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 batteries powering the OJI P~,.:11'otom 3 Vision Plus UAS, DJI S900 UAS and the 3DRobotics Solo provide 

approximately 15 minutes of po~:;.:red night. Witilout an exemption from 14 C.F.R. 91.151, the UAS's 

flights would not be permitted. Bfcau~c, of the limitations of the DJI Phantom 3 Vision Plus UAS, DJI S900 

UAS and a 3DRobotics Solo, a long~!- time fr;jme fQ'"J\;-!,hl:c ;n oayilght VFR conditions is reasonable. CEM 

would not initiate flight unless (ccn_~idP,dng ~i:-<.1 ~nJ forecast weather conditions) there is enough power 

to fly at normal cruising speed to -th~: intendid Ia riding point and land the UAS's with 25% battery power 

remaining. 

CEM believes that an exemption from 14 C.F.R. 91.15l{a} is safe and within the scope of prior 

exemptions. See exemption 10673. Operating the UAS without 30 minutes of reserve fuel does not 

engender the type of risks that Sectioi'J91.151(a) was meant to prevent given the size and speed at which 

the UAS's operate. In the unlikely evem that the UAS's achieve a low battery 9 ;· 

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status it would simply land. Given the UAS's "Y<::-ight and construction materials, the risks are less than 

contemplated by the current regulation. 

Similar exemptions have been grantE!.d to other op~;i?~NS, including Exemptions 2689F, 5745, 10808, 

10673 and Exemptions 11062 through 11067, 11080, 1110, 11112, 11109, 11138, 11136 and 11150. 

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

Section 91.405(a) requires that an airr;raft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this and shall between required inspections, expect as provided in paragraph 

(c) of this section, have discrepancies repaired as prescribed in part 43; Section 91.409{a}(2.) requires an 

annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or 

operator to keep records showing certain maintenance work that has been accomplished by certified 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. 

Maintenance ofthe DJI Phantom 3 Vision Plus UAS, DJI 5900 UAS and the 3DRobotics Solo will be 

accomplished by the owner/operator pursuant to the manuals attached as confidential exhibits. An 

equivalent level of safety will be achieved because UAS's are small and light will carry a small payload, 

will operate in restricted predetermined areas and is not a complex mechanical device. The operator will 

ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep 

a log of any maintenance that is performed; moreover, the operator is the person most familiar with the 

aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent 

level of safety. The FAA has granted-exemptions for similar operations in Exemptions 11062 through 

11067, 11080, 11109, 11110, nu:.. .. 11136 and 11138.10 ,_ ~,. 

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Limitations and Conditions 

The limitations and conditions for which Chad Medford Video Production agrees to be bound when 

conducting commercial operations under an- FAA issued exemption include: 

1. Operations of the UA is limited to the aircraft described in the attached manuals which are miniature 

rotor aircraft. 

2. The UA may not be flown at an indlc.;ted airspeed exceeding 50 knots. 

3. The may be· operated an altitude of no mme than 400 feet above the ground level. All altitudes 

reported to Air Traffic Control (ATC) must be in ft::£;~ AGI. 

4. The UA must operate within visu~i line of sight (VLOS) of the pilot-in-command (PIC) at all time,s. 

5. All operations must utilize a visual observer. The visual observer (VO) may be used to satisfy the VlOS 

requirements as long as the PIC always maintains VlOS capability. The VO and PIC must be able to 

communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or 

her designation for the duration of the flight, The PIC must ensure that the VO can perform the functions 

prescribed in the operator's manuals.,. . 

6. The manuals must be amended to include all conditions and limitations required by the FAA. The 

manuals must be maintained and made available to the administrator upon request. 

7. The PIC must inspect the UA to ensure it is in a comlition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UA, the aircraft is prohibited from operating until the 

' necessary maintenance has been performed, and the UA is found to be in a condition for safe flight. All 

maintenance and alterations will be properly documented in the aircrafts records. 

8. The PIC who conducts the functional test flight after the UAS has undergone maintenance or 

alterations that affect the UAS's oper.ation, must make an entry in the UAS aircraft record. 

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9. The preflight inspection must acco~nt for all discrepancies not covered in the relevant preflight 

inspection sections of the operator',~ manuals. 

10. The operator must follow the :t:.w;dacturer's UA aircraft/component, maintenance, overhaul, 

replacement, inspection and life :,mit requir~ments, with particular attention to flight critical components 

that may not be addressed in the mandacturer's manuals. 

11. The operator must carry out its mai~1t~nai1Ce, jnspections, and record keeping requirements in 

accordance with the manuals. Ma?nt·mimce, ic"'Spt:ction and alterations must be noted in the aircraft 

records, including total flight hours, d~cription of work accomplished, and the signature of the 

authorized technician returning the UAS to service. 

12. The authorized technicians must receive and document training referenced in the manuals. 

13. Each UAS operated under the exem!Jtion must comply with all manufacturer system and safety 

bulletins. 

14. Operator's maintenance personnel must f-f;ake a record entry in the UAS logbook or equivalent 

document of the corrective action taken againstl{i·i~aep~ncies discovered between inspections.· 

15. The PIC must possess at least a private pilot certificat~''and a third-class airman medical certificate. 

The PIC must also meet the flight review requirements specified in 14C.F.R. 61.56 as to the UAS. 

16. The operator may not permit and-PIC to operate ~nless that PIC has demonstrated through 

Chad' straining and currency requirements that the PiC is able to safely operate the UA in a manner 

consistent with how the UAS will be operated under this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

17. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within or controlled-access property and land or be recovered in accordance with the manuals. 

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18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the manuals. 

19. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

condition) there is enough power to at normal cruising speed to the intended landing point and land the 

UA with 25% batter power remaining. 

20. The operator will file a request for a Notice to Airmen (NOT AM) not more than 72 hours in advance, 

but not less than 48 hours prior to operation. 

21. All aircraft operated in accordat·~.:e with the exemption must be identified by serial number, 

registered in accordance with 14 '~-.FR. 9.art 47 and have identification (N-Number) markings in 

accordance with 14 C.F.R. Part 4'\ Su.bpart c:Markings must be as large as practicable. 

22. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Cql.mn~ssion ("FCC") or other appropriate government 

oversight agency requirements. ·.' . l · ' · , _: · ·:o- · ··.:..· 

23. The documents required under 14 C:f.R. '91.9 and 91.203 must be available to the PIC at the ground 

control station of the UAS any time the aircraft'ls operating. These documents must be made available to 

the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and yield the right of way to all other manned operations and activities at 

all times (including, but not limited to, ':.Jtralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.). 

25. The UAS may not be operated by the PIC f~~·i;·J._:~y ~oving-device or vehicle. 

26. UAS operations may not be conducted during night, o.~ defined in 14 C.F.R. l.l.AII operations must be 

conducted under vis_ual meteorological conditions r'VMC"). The UA may 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. 

27. During operations in Class G airspace, the UA may not operate within 5 nautical miles of geographic 

center of an airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport's management is obtained, and the 

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operation is conducted in accordance with a NOT AM aJ !'!!quireo by the operator's COA. The letter of 

agreement with the airport management must be made a~ailable to the Administrator upon request. 

28. The UA may not be operated over congested or ~ensely populated areas unless the conditions set 

forth in #31 are satisfied. These poputated areas include~ but are not limited to, the yellow areas depicted 

on World Aeronautical Charts ("WAC'', Sectional Aeronautical Charts ("Sectionals"), or Terminal Area 

Charts ("TAC"}. However, it is the PIC's responsibility to'maintain safe altitudes required by 91.119. 

29. Operations must be conducted at least 500 feet from all nonparticipating persons {persons other than 

the PIC orVO), vessels, vehicles and structures unless: 

111 Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the 

event of an accident. The operator must ensure that nonparticipating persons remain under such 

protection. If nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately; and/or 

rn 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 

object; and 

~Operations near the PIC or VO ~? ~~~t present an undo hazard to the PIC or VO, per 91.119(a). ~ > ~ ~ \ 

30. All operations shall be conducted ove(private or controlled access property with permission from the 

land owner/controller or authoriz,,:d re;Jr~s.entatiye will be obt~fhed for each flight to be conducted. · 

31. In the event COA's are require:t:1 an~' incid.eh~,. <icddent or flight operation that transgresses the lateral 

or vertical boundaries of the operdttonal are.:-· as defined by the applicable COA must be reported to the 

FAA's UAS lntegration.Office ("AFS-80") withiri 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB") per instructions contained on the NTSB website: www.ntsb.gov. 

Thank you for your consideration, 

Chad Medford 

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