BRYAN KOSS, LLC 310.499.8141 • BRYANKOSS@GMAIL.COM • 17851 VALLEY VISTA BLVD • ENCINO, CA 91316 • BRYANKOSS.COM

COMMERCIAL, TELEVISION, DOCUMENTARY, FILM, STEREOSCOPIC , VR-360 PRODUCTION

I would like to submit a petition for an exemption to the Federal Aviation Administration (FAA) under 

Section 333 of the FAA Modernization and Reform Action of 2012 for the purpose of allowing my business 

and me to engage in Aerial Cinematography, Aerial Videography and Aerial Photography.

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)

14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and14 

CFR Part 11, Bryan Koss, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, 

provided such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would provide professional services in the followingareas:

1. Aerial Cinematography, photography and/or video for public and/or private use 

including Commercials, Television, Documentary, Film, Public Events and 

Newsgathering, and other related professionalactivities.

2. Aerial Cinematography, photography and/or video for public and/or private use including real 

estate and architecture.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and celltowers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would permit the operation of designated UAS 

as set forth in this document under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) safe. Approval of this exemption would increase public

awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace system
I plan to operate the following:

(1) A UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft (UA or Phantom 

3) and a transportable ground station. The Phantom 3 is referred to as a quad-copter with a maximum gross 

weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by 

batteries. The UA has a maximum airspeed of 16m/s.

2) A UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or Inspire

1) and a transportable ground station. The Inspire 1 is referred to as a quad-copter with a maximum gross 

weight of about 6.5 pounds. It is equipped with four rotors that are driven by electric motors powered by 

batteries. The UA has a maximum airspeed of 22 m/s.

Also, given the small size of the UAS’s involved and the restricted controlled environment within which 

they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national security issue. Given the following, 

the grant of the requested exemptions is clearly in the public interest: James Bender proposes that the 

exemption requested herein apply to civil aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which James Bender agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:

1) The UAS will weigh less than 55 lbs.

2) Flights will be operated within line of sight of operator.

3) Maximum total flight time for each operational flight will be 30minutes.

4) Flights will be terminated at 15% battery powerreserve.

5) Flights will be operated at an altitude of no more than 400 feetAGL

6) UAS operator will be trained and certified in the proper safety and operations of the UAS.

7) The UAS will only operate within a controlled area as defined in the Procedures.

8) The operator will post advisor notice around the controlled area.

9) The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated asrequired.

10) If the UAS loses communications or loses its GPS signal, the UASwill have capability to 

return to a pre-determined location within the Security Perimeter andland.

11) The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. 

We look forward to working with your office. Please contact us at any time if additional information or 

clarifications are needed.

Sincerely,

Bryan Koss

310.499.8141