Sept 28

th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Dream About Drones, LLC for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, Dream About Drones, (Dream) hereby applies for an exemption from the Federal Aviation 

Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles 

(i.e., "small unmanned aircraft" or "UAS") for the purposes closed-set filmmaking and cinematography for

the film and television industry and aerial photography-videography for the real estate industry and

mapping and aerial inspections.

This petition for exemption addresses pertinent FAA FARs and CFRs, as well as but not limited to 

these accompanying Dream documents;

1. Flight Operations Manual and;

2. Operations Manuals

(collectively referred to as Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual").

1

Dream submits these as well as other Dream supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary 

information that the Dream has not and will not share with others. Additionally, these documents contain 

operating conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. §552 et seq.

 __________________________

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not 

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training 

manuals, service information letters and, safety/service bulletins).
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This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Closed-set Filmmaking-Cinematography for the Film and Television Industry

B. Real Estate Aerial Photography, Videography and Inspection Services

III. Relevant Statutory Authority

IV. Dream Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations 

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance 

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a)

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

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

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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I. DESCRIPTION OF PETITIONER

Dream About Drones is an established photography company now working with drones to conduct

photography and video for the regional film television industry and the commercial and residential real 

estate market. Closed-set filmmaking and cinematography for the film and television industry and aerial 

photography-videography for the agriculture and real estate industries, as well as for mapping and aerial 

inspections The company has worked to provide regional residential and commercial aerial inspections, 

mapping, and surveys. The Company also conducts video shoots for those needing promotional footage of 

their properties for marketing and construction planning purposes. Dream About Drones is also a local for 

hire crew for the film and television industry prepared to conduct on set shoots. Petitioner is located in 

Atlanta, GA, an increasingly robust location for the film and television industry. The David Smith the 

company Principal has been flying sUAV’s for more than a year without incident.

The contact information for Petitioner is as follows: 

Dream About Drones, LLC.

Attn: David Glenn Smith

165 Courtland St. NE.

Atlanta, GA 30303

Phone: 404.369.4711

Email: dave@dreamaboutdrones.com

II. DESCRIPTION OF PROPOSED OPERATION

Dream About Drones seeks an exemption pursuant to Section 333 of the Reform Act to operate the

DJI Inspire 1, DJI Phantom 3, DJI Phantom 2, and a DJI S1000 the (DAD-UAS) for the proposed

operations discussed below. All UAS operations will occur under tightly controlled conditions on 

private property where Dream has received permission to operate from the landowner, controller or 

authorized representatives. The proposed UAS operations will be conducted in accordance with the

conditions and limitations of this Petition for Exemption and DREAM’s Operations Manuals. As detailed 

in Dream’s Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within 

visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 miles 

away from an airport. Moreover, Dream’s Operations Manuals incorporate redundant safeguards to 

assure that the aircraft does not travel outside the controlled area of UAS operations, including GPS

"geo-fencing" technologies.

A. Closed-set Filmmaking and Cinematography

Dream seeks to use small DAD-UAS for the purpose of conducting scripted, closed-set filming for

the motion picture, television, and web industry.
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HeliVideo Productions, LLC (Exemption No. 11065)

Snaproll Media, LLC (Exemption No. 11063)

RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

Flying-Cam, LLC (Exemption No. 11080)

Aerocine, LLC (Exemption No. 11150)

Team 5, LLC (Exemption No. 11158)

Alan D. Purwin (Exemption No. 11161)

Helinet Aviation Services, LLC (Exemption No. 11160)

Picture Factory, Inc. (Exemption No. 11178)

Dronair Solutions (Exemption No. 11671)

All UAS filmmaking and television film production operations will be conducted on private property 

in a controlled area, away from spectators and persons not involved in the film and TV production. All 

UAS filming will be conducted during daylight hours, VFR conditions, at altitudes below 400' AGL. As 

set forth below, Dream About Drone’s operations provide a superior level of safety and quality compared

to performing the same filming work using conventional fixed-wing aircraft or helicopters.

B. Real Estate Aerial Photography, Videography and Inspection Services

Dream seeks to use small DAD-UAS for the purpose of conducting aerial photography, videography and 

inspection services for the real estate industry. Traditional methods of inspection this of structures, expose

inspectors and the video crew to higher risks of serious injuries, or death. Inspectors need to climb roof tops

or otherwise perform elevated work, which exposes them to the risk of dangerous falls, electrocution or 

other work related extremes. In addition, depending on the nature of the inspection, proximity to equipment, 

and other mechanical hazards associated with industrial sites and construction facilities often involves a risk 

of exposure to hazardous. The use of small DAD-UAS mitigates these hazards and is ultimately a much 

safer method of performing these and most other types of inspections.

Small UAS inspection is also safer than traditional manned aircraft performing the same function. 

Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks 

associated with vehicles weighing thousands of pounds and carrying passengers and large amounts of fuel. 

It is important to note that the use of small UAS in this area will not only be safer and more cost effective, 

but the quality of collected data and information is far superior.
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Small UAS inspection is more reliable, and allows for the collection, dissemination, and storage of visual 

and other sensory data with greater precision and duration. Small DAD-UAS are also capable of accessing

and inspecting areas that would otherwise be inaccessible to humans or cannot be completed with

conventional aircraft or other inspection methods.

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate

in the National Air Space ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

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

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

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) 

(permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) 

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing 

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. DREAM ABOUT DRONE’S PROPOSED UAS OPERATIONS MEET THE

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The small UAS operations proposed by Dream in this Petition for Exemption qualify for expedited 

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are 

satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational

Capability

A Grant of Exemption is appropriate for operations conducted using the DAD-UAS due to its size

weight, speed, and operational capability.
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The UAS have been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

The UAS weigh less than 55 pounds, including payload.

The UAS will not be flown at a ground speed in excess of 50 knots.

Altitude information will be generated by equipment onboard the UA as specified using GPS 

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

The DAD-UAS will have system redundancies and independent functionality to ensure the overall 

safety and predictability of the system. If connection to the remote control or ground control station 

is lost, failsafe systems will permit the UAS to return to a predetermined location and safely land 

without injury or damage.

The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency 

requirements. The operating frequency for the DJI Phantom II and a S1000+ is 2.4 GHz.

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed

6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference in 

weight between the DJI Phantom II and a S1000+ and a helicopter significantly reduces the potential harm 

to the participating and non- participating individuals or property in the event of an accident or incident. In

addition, the risk to the onboard pilot and camera operator is eliminated.

2See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of 

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161);

Grant of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).
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B. Approval is Warranted Based on the Operational Restrictions Set Forth in Dream’s

Operations Manuals

Dream’s Operations Manuals and the Manufacturer's Manual for the selected DAD-UAS will contain 

all the procedures and limitations necessary to safely and successfully perform the operations specified in

this Petition for Exemption. To assist the FAA in making a safety assessment of Dream’s proposed 

operations, below is a summary of operational limitations and conditions that Dream will adhere to, and 

which will ensure an equivalent or higher level of safety to operations conducted under current regulatory 

guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight operation.

3. All DAD-UAS operated under the Grant of Exemption 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 as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. 

The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the Dream’s 

Operations Manuals.
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The Operations Manuals will be maintained and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations in the Grant of Exemption and Dream’s 

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence 

and must be followed. Otherwise, Dream shall follow the procedures outlined in their Operations 

Manuals.

10. Dream may update or revise its Operations Manuals. Revisions will be tracked and a revised copy

of the Manual will be provided to the Administrator upon request. Dream will also present an updated

and revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption. If

an update or revision would affect the basis upon which the FAA grants the exemption, Dream will

seek an amendment to its Grant of Exemption. Dream will contact the FAA’s UAS Integration Office

(AFS-80) if questions arise regarding updates or revisions to the operating documents.

11. Dream’s Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

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

weather conditions) there is enough power to fly to the first intended point of landing, and assuming 

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the DJI Phantom II and a S1000+ 

will be limited to 40 minutes or the amount of time the UAS can be flown and still maintain a reserve 

battery power of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter 

navigable controlled airspace without prior written authorization and approval from the FAA. In the 

event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than

100 feet above the highest point on the structure, and no more than 50 feet horizontally from the 

structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures 

unless:

a) Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must 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 UA, flight operations must cease 

immediately and/or;
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b) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and;

c) Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

16. 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 three statute miles from the PIC.

17. The UA may not operate within 5 nm 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 as required by the Dream

COA. The letter of agreement with the airport management will be made available to the 

Administrator upon request.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for 

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. The 

PIC shall not operate the UAS if the inspection reveals a condition that affects the safe operation of 

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

condition for safe flight. The ground control station shall be included in the preflight inspection. 

All maintenance and alternations must be properly documented in the UAS records as required by 

Dream’s Operations Manuals.

19. Dream will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in 

the UAS records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service.

20. 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 Dream’s Operations Manuals. The PIC who conductsthe functional 

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

proceduresfor a functional test flight and UAS record entry shall be included in the Dream’s 

Operations Manuals.
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21. The UAS will be operated and maintained according to the Manufacturer's Manuals and any 

required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements 

on Dream’s Operations Manuals.

23. Dream will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles 

or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time 

as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 

logged hours as UAS pilot operating the make and model of UAS to be utilized for operations under 

the exemption and thirty take-offs and thirty landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under

Special Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAs will not be operated from an elevated platform or moving device / vehicle.

35. 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.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of 

the Act, including DAD-UAS, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.

3

Dream seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using 

a UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption is sought.

4

 _________________________________________________

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at that provided by the rule from which you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, 

however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the 

requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Dream’s use of the DJI Phantom II and a S1000+ is safe when taking into account their size, 

weight, speed, and operational capability. As set forth in the description of proposed operations in Section 

IV (A), the DJI Phantom II and a S1000+ weighs less than 55 pounds, including payload and will not be 

flown at a ground speed in excess of 50 knots. UAS is also equipped with safety features that will allow 

Petitioner to operate the UAS safely after experience certain in-flight contingencies or failures.

6 7

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3):

"The DJI Phantom II and a S1000+ have the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is 

also able to respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety 

features provide an equivalent level of safety compared to a manned aircraft performing a similar 

operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5):

The DJI Phantom II and a S1000+’s can be operated entirely by a touch-screen, map-based interface. This 

means the operator only needs to command the system where to go, and the system does all the flying for 

the operator. The DJI Phantom II and a S1000+ can be operated in both semi and fully autonomous flight 

modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In 

addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot

enter areas

{footnote continued}
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Additionally, the DAD-UAS carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in Dream's Operations 

Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. Dream will also provide the FAA with advance notice of all operations via

NOTAMs as required by the applicable COA. In all cases, operation of the DJI Phantom II and a S1000+ 

under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating 

with an airworthiness certificate.

Lastly, the DAD-UAS do not need a means to communicate with other aircraft or ATC, because 

those capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.8 In

addition, no sense-and-avoid technology is necessary for the DAD-UAS because they will be operated at 

all times in VFR conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that Dream's small DAD-UAS would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent 

fault handling which allowsthe Phantom II and S1000+ to detect a system fault while in the air and

automatically fly back to its takeoff location and land. Faults that can be detected include: loss of

communication; exceeding pre-set wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to 

navigate. At any point if the operator is not explicitly commanding the system to move, the system 

automatically holds its GPS position. The flight control system employs not only GPS positioning but a 

variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure 

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly away' 

or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id.
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airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements

Dream seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides 

that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than two inches nor more than six inches high, the words 

"limited," "restricted," "light-sport, "Experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identification (N-Number) markings in accordance 

with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by Dream will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.11

________________________________________

10FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

Dream seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R.

§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft 

with an airworthiness certificate, which the UAS to be operated under this grant of exemption will not

have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service 

Bulletins. Further, as required by Dream’s Operations Manuals, the PIC will conduct a pre-flight 

inspection of the UAS and all associated equipment to account for all discrepancies and/or inoperable 

components. Maintenance will be performed and verified to address any conditions potentially affecting 

safe operation of the UAS and no flights will occur unless, and until, all flight critical components of the 

UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight-critical components. As required by Dream’s 

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the UAS aircraft 

records of the flight.

Dream’s Operations Manual also includes requirements to follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the 

following applicable components: powertrain system (powerplant), propellers, avionics and control 

surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including 

batteries), ground control station, hazard accessories, and spare parts. Further, Dream’s Operations 

Manuals also includes procedures to document and maintain a record of the UAS maintenance, 

preventative maintenance, alterations, and status of replacement /overhaul component parts, and the total 

time in service of the DAD-UAS used under this Grant of Exemption. As a whole, the maintenance and 

inspection procedures required in Dream’s Operations Manuals ensure that an equivalent or higher level 

of safety will be achieved.
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PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Dream seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical 

certificate.The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the

airspace in which the PIC will be operating, as well as requiring certifications if the private pilot is 

carrying passengers or cargo for hire. In this case, while the DAD-UAS will be operated as part of a

commercial operation, it carries neither passengers nor cargo.

In the Grant of Exemption to Astraeus Aerial.12, the FAA determined that the unique characteristics 

of UAS operation outside of controlled airspace did not warrant the addition cost and restrictions attendant 

with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The 

fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot 

would not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The Dream restrictions have placed on its UAS operations meet or exceed the restrictions similarly 

imposed on Astraeus Aerial. Dream will operate on private property away from persons and property not 

involved in the operation. Dream will also obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 

NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Dream will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will 

have experience not only in UAS operations generally but have logged flight time in the specific make and 

model used for the operations before they are permitted to participate in commercial flights on behalf of 

Dream. The pilot qualification, training, and currency requirements in the Operations Manuals ensure that 

Dream pilots are competent and proficient in the UAS they are operating. Dream’s training and 

qualification requirements are consistent with those contained in prior FAA Section 333 Grants of 

Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety.

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the DAD-UAS, Dream seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be 

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and

14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin

or cockpit entrance so that it is legible to passengers or crew.

13See id. at 13-14, 22
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Given the small size and configuration of the DAD-UAS, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the UAS because there is simply no room

and the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be 

achieved by ensuring that the pilot has access to the documents at the ground control station from which he 

or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Dream seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Dream’s Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the Dream’s Operations Manuals, including checklists covering

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather,

flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency

landing areas—before initiation of flight. Dream’s Operations Manuals and the Manufacturer's Manual

will be kept at the ground control station and will be accessible to the PIC at all times while operating the 

UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
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Dream seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." DAD-UAS and remotely piloted aircraft, by their

design, do not have functional dual controls. Instead, flight control is accomplished through the use of a

device that communicates with the aircraft via radio communications. Accordingly, an exemption will be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the DAD-UAS that Dream intends to use, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard the UAS, 

and as required by the Dream’s Operations Manuals, all persons will be a safe distance away in the event 

that the UAS experiences any difficulties during flight instruction. Moreover, as required by the Dream’s 

Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a 

whole, the safety procedures provided for in Dream’s Operations Manuals ensure that the proposed UAS 

operations provide an equivalent or higher level of safety than that provided by the flight instruction 

regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Dream requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less 

than those minimum altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur below

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 

feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and 

within 50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the

Pilot and/or Observers(s) may need to be less than 500 feet away from the UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency 

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from §

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a 

tree Aerial (FAA-2014-0534 at 15).
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Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the DAD-UAS, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the DAD-UAS, as well the

controlled location where the operations will occur. In order to avoid any risk to manned aircraft, 

flight operations will be restricted to 400 feet AGL or below, or when inspecting a structure whose 

height exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet 

horizontally of the structure.

As set forth in the Operations Manuals, the DAD-UAS will be operated in a restricted area, and all

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless

that person is in a position where he or she is shielded from the UAS and any possible debris resulting 

from UAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating 

person within 500 feet of the UAS leaves a shielded position. Further, UAS operations will occur at least

500 feet away from vehicles or structures unless the property owner/controller has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects and, operations near 

the PIC or Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in 

Dream’s Operations Manuals will ensure operations can be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

Dream seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that the DAD-UAS do not 

have a barometric altimeter, but rather a GPS altitude read out.

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or 

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such 

protection. The operator must also 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 UA, 

flight operations must cease immediately. When considering how to immediately cease operations, the 

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any 

such vessels, vehicles orstructures grants permission for the operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard.”
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The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121

can be achieved in circumstances where: (1) the DAD-UAS will be operated below 400 feet AGL or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The DAD-UAS that Dream intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Dream’s Operations Manuals, the PIC will be required to

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the DAD-UAS Dream to use, and the safety mitigation procedures contained in the

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of

Exemption to the requirements of § 191.121 is therefore appropriate.

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

Dream requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin 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.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more 

than 100 feet above the highest point on the structure.

 18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
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Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a DJI Phantom II and S1000 flight unless (considering wind and 

forecast weather conditions) there was enough power to fly to the first intended point of landing and,

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the 

FAA considered that the UAS batteries for the DJI Phantom II and S1000 provided provide approximately 

20 minutes of powered flight (with payload) and provided battery level and battery time remaining in 

minutes and seconds to the PIC.

19 The FAA also considered the fact that the DJI Phantom II and S1000 

operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and that in the 

event that the UAS should run low on power, the PIC will be alerted and can land the DJI Phantom II and 

S1000 as soon as possible. Like the VDOS Grant of Exemption, Dream’s use of the DJI Phantom II and 

S1000, combined with the requirements of Petitioner's Operations Manuals, ensure that an equivalent level 

of safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the DJI Phantom II and a S1000+ unless (considering

wind and forecast weather conditions), there was enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 25% battery power remaining. Dream will adhere to this 

limitation for DJI Phantom II and a S1000+ flights.

The DJI Phantom II and a S1000+ includes a low battery warning system and the amount of battery 

reserve power remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS 

to a ground-based-on-screen display.

20 As required by Dream’ Operations Manuals, the PIC will promptly 

fly the UAS back to the home launch location or pre-determined abort location where the UAS may safely 

land, while still maintaining a minimum of 25% reserve battery power. Dream submits that the procedures 

requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighting less than 

55 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide 

an equivalent or higher level of safety to that provided by the regulations from which exemption is sought.

19Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20The DJI Phantom II and a S1000+ ground control station displays, the DAD-UAS position, navigation 

route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target position,

date/time, and sensor heading and orientation relative to the UAS.
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VI. DRUG AND ALCOHOL PROGRAM

Dream will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting Dream’s Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improves safety and 

reduces risk, harm and serious injury to the team, the production crew and the general public. Traditional

methods of aerial cinematography/videography involves large and loud helicopters and aircraft, often 

flying in densely populated regions. Camera operators and crew are put in positions of high risk, needing 

to work in the air, and within the confines of small or restricted air, ground, and geographic space. The use

of small DAD-UAS can eliminate or mitigate these risks, and are ultimately a safer and more effective 

method of performing these types of shoots and inspections. 

The use of small DAD-UAS also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the DAD-UAS carry no 

passengers or crew. Further, in the unlikely event of an accident, Dream’s small battery powered DADUAS present significantly less danger to persons on the ground when compared to operations by

conventional manned aircraft.

21 As Petitioner's DAD-UAS are battery powered, the public will also benefit

from a reduction in harmful emissions associated with conventional aircraft performing in the same 

functions proposed herein. Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to 

filmmakers, DAD-UAS provide an additional tool for the aerial filming industry, adding a greater degree

of flexibility, which supplements the current capabilities offered by manned aircraft. _______ _____________ 22

________ 

____________________

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12):

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh 

less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard 

pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming 

operation."
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DAD-UAS provide an additional tool for the aerial photography industry, adding a greater degree of

flexibility, which supplements the current capabilities offered by manned aircraft.

22

VIII. PRIVACY

All Dream’s UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a);

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a)

& (b).

The exemption will enhance safety by reducing risk to the general public and property owners 

from the substantial hazards associated with performing equivalent for the purposes of closed-set 

filmmaking and cinematography for the film and television industry, and aerial photographyvideography for the real estate industry and mapping and aerial inspections with conventional fixed-wing

aircraft, rotorcraft, or other methods.

X. CONCLUSION

Dream’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act 

of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed UAS operations will benefit the public as a 

whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration of 

the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing Dream use small DAD-UAS for closed-set and aerial 

filmmaking- cinematography for the film and television industry; aerial photography-videography services 

for corporations and mapping and aerial inspections.

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

David Glenn Smith

Dream About Drones, LLC

165 Courtland St. NE. Suite A-203

Atlanta, GA 30303

Phone: 404.369.4711

Email: dave@dreamaboutdrones.com

(The following attached items contain and commercial information exempt from disclosure under the

Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14

C.F.R. § 11.35(b)).

Attachments:

1. MPTOM Motion Picture and Television Operations Manual

2. General Operations Manual

3. PIC Operating Manual

4. Dream Protocols

5. Location Protocols

6. Flight Communications Protocols

7. Departing Location Protocols

8. Transmitter Protocols

9. Preflight Checklist

10. Post Flight Checklist

11. Equipment Checklist

12. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals