U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington DC 20590 

Re; Exemption Request Section 333 of the FAA Reform Activities 

Dear Sir/Madam, 

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

14 C.F.R Part II, Starfruit Productions, a Florida limited liability company operating Small 

Unmanned Aircraft Systems (sUAS) equipped to conduct areal photography and survey for 

various industries, hereby applies for exemption from the Federal Aviation Regulations (FARs) 

listed below to allow operation of our sUAS commercially in airspace regulated by the Federal 

Aviation Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption is similar to previous FAA issued grants of exemption including but 

not limited to Exemption Nos 11602, 11109, 11112, 11213, 11295. 

Our commercial activities would include: 

The requested exemption would permit Starfruit Productions LLC to pursue its commercial 

interests in providing services to consumers interested in training, research, and areal data 

capture using a small advanced sUAS in the following areas: 

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Aerial photography and Videography for the wedding, real estate, construction and 

utilities industries 

Agricultural Surveying and Application 

sUAS Operator Training 

Product Demonstrations 

Research and Development 

All Starfruit Production sUAS flights will occur over private or controlled access property. 

Will do so with the owner's prior consent and knowledge. Only people who have consented or 

otherwise have agreed to be in the area where photography and videography will take place 

will be captured in any photos or videos. 

Additionally, all Starfruit Productions pilots will hold an airline transport, commercial, private, 

recreational, or sport pilot certificate and also hold a current FAA airman certificate or a valid 

U. S. Driver's license issued by a state, the District of Columbia, Puerto Rico, a possession, or 

the Federal government. If an observer is not a qualified pilot they will be trained by Starfruit 

Productions pilots to understand the proper roles, of an observer, communication procedures, 

proper visual scan techniques, operations at non-towered airports, and appropriate sections of 

the Aeronautical Information Manual. 

The petitioner Requests Relief From the following regulations: 
Regulations from which the exemption is requested: 14 CFR 61.23(a) and (c), 61.10l(e)(4) and 

(5),61.113(a)(l) ans (2), and 91.7(a), 91.109, 91.119(c), 91.121, 91.15l(a)(l), 91.215, 

91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extent necessary to 

allow Starfruit Productions to operate a sUAS to perform training, research, and areal data 

collection. 

We are petitioning for exemption to enable Starfruit Productions to operate a series ofUAS 

platforms that have been previously approved by exemption. Namely: 

DJI Phantom 2 

DJI Phantom Vision 

DJI Phantom Vision+ 

DJI Inspire 

DJI SlOOO 

DJI S900 

DJI Flamewheel 550 

eBeeAG 

3D Robotics IRIS+ 

RF-70 

DJI Phantom 3 Professional 

DJI Phantom 3 Advanced 

Exemption 113 98 

Exemption 11310 

Exemption 113 98 

Exemption 11398 

Exemption 11416 

Exemption 1140 1 

Exemption 11397 

Exemption 11339 

Exemption 11419 

Exemption 11295 

Similar to Exemption 11310 

Similar to Exemption 11398 

These sUAS all weigh less than 55 pounds, have a built incapability to limit the height flown 

above the ground, to limit the radius of the distance from the operator and to exclude it from 

Class B, C and D airspace including a no fly zone feature. Each system also has a failsafe 

function of the autopilot system, which when communication between the Main Controller and 

the transmitter is lost, the system will automatically trigger return to home and will land safely. 

This submission does not include the operating manuals for each model requested above. As 

they have been reviewed by the Administrator in granting previous exemptions. Copies of all 

Operating Manuals will be provided on request. It should be noted that while the FAA has not 

granted an exemption for the Phantom 3 series, it is an upgraded version of the Phantom 2 

including components of the DJI Inspire 1. 

The above specifications meet standards listed below: 

• Starfruit Productions will only operate its sUAS in line of sight of a pilot and/or an 

observer and will operate at sites that are a 'sufficient distance' from populated areas 

within the sterile area described in the operators manual. Such operations will ensure 

that the sUAS will "not create a hazard to users of the national airspace system or the 
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public. 

Starfruit Productions will not operate an sUAS within 5 nautial miles of an airport 

reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) 

unless a letter of agreement with that airports management is obtained or otherwise 

permitted by a COA issued to Starfruit Production. 

Maximum flight time for any flight will be 60 minutes . 

Flights will be terminated at 20% battery power reserve should that occur before the 60 

minute limit. 

The sUAS will be programmed to set a maximum altitude of 400 AGL. 

Minimum crew will be for each operation will be the sUAS pilot who will keep the 

sUAS in visual line of site at all times. 

The sUAS pilot PIC's (Pilot In Command) will hold an Airline Transport, Commercial, 

private, recreational, or sport pilot certificate and also hold a current FAA airman 

medical certificate or a valid U.S. drivers license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal Government. 

The sUAS operated by the petitioner weighs less than 55 pounds including the payload 

(i.e. camera, gimbal, and lens). 

The sUAS will operate at speeds of no more than 55 knots . 

Given the small size of our sUAS and the restricted sterile environment which they will 

operate, out sUAS operations adhere to the Reform Act's safety requirements. 

Additionally, the fact that the Starfruit Productions pilots hold FAA Pilot certificates 

demonstrates they have the highest regard for safe operations with an understanding of FAR's 

pre-flight inspections, maintenance requirements and repairs, operations within regulated 

airspace as well as highly trained to high safety standards. 

Under the requested exemption Starfruit Productions will ensure all operators have completed 

a small unmanned aircraft systems (UAS) education and training program including all 

applicable regulations and guidance documents. Including aeronautical background 

information such as Charts, NOTAMS, Aircraft Circulars; Radio Communication Procedures; 

Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather 

factors; Airmanship and Decision Making; and Safe Operating Procedures. We respectfully 

request exemption under section 333 to enable Star Fruit Productions to operate safe, low risk 

commercial sUAS operations for the activities stated. RFS at all times will respect the space 

and privacy of citizens and property whilst keeping our skies safe. 

Exemption Requests and Equivalent Level of Safety 

Starfruit Productions requests an exemption for the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAS: 
14 CFR 61.23 Medical Certificates 

The regulation provides that a person requires a first or second class medical certificate to act 

as pilot in Command of an aircraft for compensation or hire. Our proposed operations require 

that the PIV must hold a current FAA airman medical certificate or a valid U.S. drivers license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. Since the aircraft can not carry passengers or property, we feel we meet the intent 

of 61.23 even though the intent of this application is to conduct business. 

14 CFR 61.101, 14 CFR 61.113, and CFR 61.315 Pilot privileges and Limitations 

The regulation holds that no person that holds a Recreational Pilot, Sport Pilot or Private Pilot 

certificate may act as pilot in command of an aircraft for compensation or hire. Our proposed 

operations require that the PIC must hold at least airline transport, commercial, private, 

recreational or sport pilot certificate. Since the aircraft cannot carry passengers or property we 

feel we meet the intent of 61.113 Subparagraph (b) even though the intent of the application is 

to conduct business. 

14 CFR 91.7 Civil Aircraft Airworthiness 

This section prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91,109 Flight Instruction; Simulated instrument flight and certain flight tests. 

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." During training we have the 

ability to provide dual controls utilizing two transmitters with a wireless link between the 

transmitters. One transmitter will be designated the master transmitter and the other transmitter 

is designated the slave. The PIC instructor, utilizing the master transmitter, will at all time be 

able to assume control of the sUAS. 

14 CFR 91.119 Minimum Safe Altitudes: General 

The regulation states that over sparsely populated areas the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle,s or structures. Since the typical mission of the 

sUAS would be photography or survey of persons, vessels, vehicles, or structures it would be 

necessary to operate closer than 5oofeetto the items listed. Operations will only be be flown 

over property or persons where permission has been obtained and careful pre-planning has 

been accomplished. The aircraft will be operated at a low altitude allowing, if power failure, an 

emergency landing without undue hazard to persons, or property on the surface. Therefore we 

maintain that due to the small size of the sUAS the hazard to persons, vehicles, and structures 

is minimal compared to manned aircraft, which should be considered in granting the 

exemption. 

14 CFR 91.121 Altimeter Settings 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within lOONM of the aircraft. The sUAS will fly below 400 feet 

AGL and will not need to maintain cruising altitudes in order to prevent conflict with other 
aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the sUAS on board computer to the display screen held by the PIV, providing a 

constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions 

The regulation provides that no person may begin flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly 

after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and maximum 

flight duration from a single battery charge is 15-45 minutes (depending on the sUAS) 

minutes with a 20% reserve. Since the aircraft will never fly more than Y, NM from the point 

of intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 min 

reserve and ask that our reserve will be to fly the mission to the point of intended landing and 

have a minimum reserve of 20% after that. 

14 CFR 91.215 ATC transponder and altitude reporting equipment and use 

This regulation states all aircraft operating within 30 NM of class A, B and C airspace must be 

equipped with automatic pressure altitude reporting equipment having mode C interrogations. 

Due to the small size and lifting capabilities of our sUAS we can not carry a traditional 

transponder. All our operations will be below 400" when within 30 NM. 

14 CFR Subpart E (91.401-91.417)- Maintenance, Preventive Maintenance, Alterations 

The regulation provides the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under 43.7" 

after maintenance and inspection. It is our intention the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in airworthy condition prior to every flight and in 

addition, conduct detailed inspections after every two hours of flight. Maintenance performed 

by the PIC is limited to repairing small cracks replacing propellers, checking electrical 

connections and updating software and firmware of the on-board computer. All maintenance 

will be performed by the manufacturer or their designated repair facility. The PIC will 

document work performed in accordance with 91.417. We feel due to the size, construction, 

and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

How this Request is to the betterment of our Community 

The enhanced safety achieved by replacing significantly larger manned aircraft carrying crew 

and flammable fuel with small UAS carrying no passengers or crew and operated under the 

specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find 

that the UAS operations enabled by the instant Petition are in the public interest. Moreover, as 

the FAA has already recognized, "UAS provide an additional tool for the film making industry, 

adding a greater degree of flexibility, which supplements the current capabilities offered by 

traditional aircraft. 
Additionally, the unmanned aircraft can take off an land from the property we have been 

contracted to image. The ability to avoid overflying private and public properties provides the 

public with the benefit of increased safety and privacy from overhead aircraft. 

Request for Blanket CO A Approval 

On March 25, 2015 the FAA announced that it has implemented a new policy of granting 

"blanket" CO As to applicants requesting exemptions from the Federal Aviation Regulations 

under Sections 333 of the FAA Modernization and Reform Act of2012. 

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsld=82245 upon approval of Starfruit Production's 

exemption request. 

Respectful! y, 

Sage 

President 

Starfruit Productions, LLC 

51St St W, 

Bradenton, Fl 34210 

(941) 527-9522