September 18, 2015

Submission by: Aurora Imaging Company d/b/a Bowstring Studios

Sean Quinn, President

600 Old Elm Street, Ste 200

Conshohocken, PA 19428

484-342-0606

sean@bowstring.tv

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. SE

Washington, D.C. 20590

Re: Exemption request under Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations.

Dear Sir or Madam:

I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405, 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal 

Regulations (14CFR) was granted in Exemption Number 111138, 11395, 11428 

and 11434.

I will operate a DJI Phantom II, a UAS weighing less than 7 lbs. at takeoff, and can 

take photos and videos using an on-board camera. The operations preformed by 

myself with this UAS are to include, but not limited to corporate video 

videography and aerial photography, typically to gain an additional perspective on 

a special event (e.g. sporting event or concert), film subject or structure. These 

activities will always take place on/above private property with the prior approval 

of the landowner and/or event organizer.

Operations under this exemption will be conducted as outlined in the proposed rule 

set in motion on 02/23/2015 in docket FAA-2015-0150.

 Operational Limitations: Visual line-of-sight (VLOS) only; the unmanned 

aircraft must remain within VLOS of the operator or visual observer.

 At all times the small unmanned aircraft must remain close enough to the 
operator for the operator to be capable of seeing the aircraft with vision 

unaided by any device other than corrective lenses.

 Small unmanned aircraft may not operate over any persons not directly 

involved in the operation.

 Daylight-only operations (official sunrise to official sunset, local time).

 Must yield right-of-way to other aircraft, manned or unmanned.

 May use visual observer (VO) but not required.

 First-person view camera cannot satisfy “see-and-avoid” requirement but 

can be used as long as requirement is satisfied in other ways.

 Maximum airspeed of 100 mph (87 knots).

 Maximum altitude of 500 feet above ground level.

 Minimum weather visibility of 3 miles from control station.

 No operations are allowed in Class A (18,000 feet & above) airspace.

 Operations in Class B, C, D, and E airspace are allowed with the required 

ATC permission.

 Operations in Class G airspace are allowed without ATC permission.

 No person may act as an operator or VO for more than one unmanned 

aircraft operation at one time.

 No careless or reckless operations.

 Requires preflight inspection by the operator.

 A person may not operate a small unmanned aircraft if he or she knows or 

has reason to know of any physical or mental condition that would interfere 

with the safe operation of a small UAS.
I request an exemption from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) 

and (b) Maintenance Inspections since they only apply to aircraft with an 

airworthiness certificate. I will, however, perform a preflight inspection of my 

UAS before each flight as outlined in the operating documents.

I request an exemption from 91.151. The Pilot in Command will abide by the 

following personal protocols and controls:

 Operator will only operate in reasonably safe environments that are strictly 

controlled, are away from power lines, elevated lights and airports. Operator 

will conduct extensive preflight inspections and protocols as outlined in the 

aircraft manufacturer’s operating documents.

 Operate the UAS below 50 feet and within a radius distance of 150 feet from 

the controller while maintaining direct line of sight visual observation 

(VLOS).

 Land the UAS before the manufacturer’s recommended minimum battery 

level.

 Use the UAS’ GPS flight safety feature whereby the aircraft raises to a 

predetermined safe altitude and then returns to point of take off should 

communication with the remote control operator is lost.

 Contact respective airports and/or Flight Standard District Offices if 

operations will be within 5 miles and advise them of my estimated flight 

time, flight duration, elevation of flight and other pertinent information.

 Have procedures in place to abort flights in the event of safety breaches or 

potential danger.

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I 

assert that since there is currently no certificate applicable to my operation, this 

regulation is inapplicable.

91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows 

helicopters to be operated at lower altitudes in certain conditions. Operator will not 

operate the UAS above the altitude of 50 feet above ground level (AGL) and will 

also only operate in safe areas away from the public and traffic, thus providing a 
level of safety at least equivalent to or below those in relation to minimum safe 

altitudes.

91.121 Altimeter Settings is inapplicable since my UAS utilized electronic GPS 

with a barometer sensor.