airborne cams

ACExemptionRequest August 10, 2015 1

August 10, 2015

Ari Cheren

Airborne Cams, LLC

11767 W. Sunset Blvd, suite 206

Los Angeles, CA 90049

(310) 948-3042

acheren@gmail.com

Petition of Airborne Cams, LLC For 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 and 14 CFR

Part 11, Airborne Cams, LLC (AC), hereby applies for an exemption from Federal Aviation 

Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial 

system (i.e., sUAS). 

This exemption is in accordance with protocols outlined in this petition for exemption, and any 

other requirements established by the FAA pursuant to Section 333 of the Reform Act. 

This exemption would permit commercial operation by AC, which uses DJI Phantom 2, DJI 

Phantom 3, Inspire 1, and S900 to conduct sUAS flight training, education, real estate 

photography, and videography, film and movie production (including closed set filming), and 

demonstration flights. AC’s operation under the exemption will be subject to strict operating 

requirements and conditions to ensure an equivalent level of safety to currently authorized 

operations using manned aircraft and under conditions as may be modified by the FAA as 

required by Section 333. 

AC will be operated under controlled VFR conditions at low altitude in airspace that is 

permitted in accordance with AC’s approved Certificate of Authorization (COA). They will 

operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for 

competency and new FAA 333 and Part 107 commercial compliance requirements. Finally, the 

FAA ATC will approve the airspace in which the sUAS will operate in advance. 

Airborne Cams respectfully submits this request for an exemption because it operates sUAS's. 

The FAA can have confidence that the operations will be conducted at an equivalent level or 

greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the 
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Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of 

the Reform Act to “establish requirements for the safe operation of such aircraft systems in the 

national airspace system.” 

For your convenience, AC has organized this Exemption request as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

VI. Public Interest 

VII. Privacy 

VIII. Federal Registry Summary 

IX. Conclusion 

I. Petitioner's Description: 

Airborne Cams, headquartered in Los Angeles, California, is a company that provides sUAS 

support to news services, real estate photography, film and television production, education, 

and demonstration flights in a compliant and safe environment. AC plans on providing a wide 

range of services as the sUAS market expands. 

AC's goal is to operate in an accident-free environment by: 

 Demonstrating a commitment by management and all employees to operate in a 

compliant manner. 

 Identify hazards and risk while eliminating or controlling all these risks. 

 Using steps to intervene and report when unsafe work practices appear to exist. 

 Training all employees involved in flight operations to operate at the highest standard 

level.

The contact information for Petitioner is as follows: 

Airborne Cams

11767 W. Sunset Blvd., suite 206

Los Angeles, CA 90049

Member Managers:

Ari Cheren

Phone: (310) 948-3042

Email: acheren@gmail.com

II. Relevant Statutory Authority: 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the 
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ACExemptionRequest August 10, 2015 3

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

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned 

aircraft systems may operate safely in the National Airspace ("NAS") before completion of the 

formal UAS rulemaking, 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.1 

If the Secretary determines that such vehicles "may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in the 

National Airspace System". 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

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

in the public interest. 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). 

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, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service: 

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. 

III. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

The proposed operations would permit AC the use of small UAS under controlled conditions in 

airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an 

increased level of safety beyond that existing when fixed or rotor wing aircraft are used to 

accomplish the same purpose. 

1 AC’s submission 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 approval, to supply 

conditions for the safe operation of the sUAS. AC welcomes the opportunity to consult with FAA staff in order to address any 

issues or concerns that this proposal may raise that they believe may require modification. 
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ACExemptionRequest August 10, 2015 4

AC uses UASs that are multirotor, weighing less than 25 pounds including payload. They 

operate, under normal conditions, at speeds not to exceed 45 mph and have the capability to 

hover, and move in the vertical and horizontal plane. AC’s UASs will operate in line of sight, 

during daylight hours, and will only operate within a sterile area. AC will operate at or below 

400 feet AGL and will file a NOTAM for each flight operated in controlled airspace. All required 

permissions and permits would be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies prior to 

operating a sUAS. 

Given the small size of the sUAS’s involved and the restricted sterile environment within which 

they will operate, this AC’s exemption falls within the zone of safety and demonstrate an 

equivalent level of safety, in which Congress desired the FAA to permit commercial UAS 

operations by exemption pending completion of formal rulemaking. Also, due to the size of the 

sUAS’s and the confined area in which the sUAS’s will operate, approval of the application 

presents no hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in 

the public interest. 

IV. Description of Proposed Operations 

To assist the FAA in its safety assessment of AC's proposed sUAS operations, below is a 

summary of operational limitations and conditions that will ensure an equivalent or higher level 

of safety to operations conducted under current regulatory guidelines: 

1. The sUAS will weigh less than 25 pounds. 

2. Flights will be operated within line of sight of the PIC and observer. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or who 

have not signed a waiver in advance of the operation. 

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a 

Visual Observer. Additional crewmembers consist of a Pilot and a Camera Operator. 

7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone 

flight training for competency and new FAA 333 and Part 107 commercial compliance 

requirements. 

8. AC will designate a Pilot in Command ("PIC") for each mission. 

9. The sUAS will operate only within a confined "Sterile Area". 
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ACExemptionRequest August 10, 2015 5

10. Prior to the operations at a particular location, a site inspection will have been 

conducted. On the day of the mission the management person with operational control 

and the PIC will concur on dispatching of the mission. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day's missions. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the sterile area be present for this briefing. 

12. AC crew will use the checklist and callouts required in the Operations Manual. 

13. All sUAS’s will be maintained in accordance with inspection program specified in the 

manufacturer’s guidelines.

14. In the event of an accident involving an AC sUAS, they will cease operations and report 

the accident to the NTSB and AFS-80.

15. Pilot in Command and Visual Observer will at all times be able to communicate by voice.

16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel 

will have been trained and tested in accordance to FAA, NTSB, and AFS-80 best 

practices.

17. All required permissions and permits would be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies.

18. AC management will submit a written “Plan of Activities” to the local Flight Standards 

District Office (FSDO) having jurisdiction over the area of proposed filming three days in 

advanced of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return to a 

pre-determined location within the Sterile Area and land.

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

communication between the pilot and the observer.

21. The sUAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

22. AC, by following FAA, NTSB, and AFS-80 best practices, will assure no individuals’ privacy 

is violated. 

23. Procedures have been established in AC’s Operations Manual to contact ATC prior to 

operating in airspace other than G. 

V. Regulations From Which Exemption is Requested 

A 14 CFR § 91.103: Preflight Action 

B 14 CFR § 91.113: Right-of-Way Rules 

C 14 CFR § 91.119 (c): Minimum Safe Altitudes 

D 14 CFR § 91.121: Altimeter Settings 

E 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions 

F 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

G 14 CFR § 91.203: Airworthiness Certificate

H H. 14 C.F.R. § 45.23 (b). Marking of the Aircraft 
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ACExemptionRequest August 10, 2015 6

A. 14 CFR § 91.103: Preflight Action 

AC requests an exemption from the preflight actions requirements of 14 CFR 91.113 that 

prescribes the preflight actions under which aircraft may operate: 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. 

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been 

advised by ATC;

b. For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information: 

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and 

ii. For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature. 

AC will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and 

the visibility is below 3 statute miles. DJI’s sUAS’s do not have published approved Airplane or 

Rotorcraft Flight Manual containing takeoff and landing distance data. 

Equivalent Level of Safety 

In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the person having 

operational control must follow to assure that the weather will be adequate to complete the 

mission in VFR condition. Since AC operates in California where the density altitude is never 

usually above 2000 feet, UAS performance is not affected. When AC is allowed to operate in 

other parts of the United States the UAS used in those locations will be test flown at gross 

weight to test performance limitations prior to conducting commercial operations. 

B. 14 CFR 91.113: Right-of-Way Rules 

AC request an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each 

person operating an aircraft so as to see and avoid other aircraft. When a rule of this section 

gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass 

over, under, or ahead of it unless well clear. 

Airborne Cams operates small pilotless UAS’s and cannot comply with these rules as they have 

been written. 
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Equivalent Level of Safety 

AC operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal operating 

altitude of other aircraft. AC management require that a Pilot in Command with experience will 

oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC 

in looking for aircraft entering the operations area. It’s the responsibility of the PIC to cease 

operations and land the UAS immediately whenever and aircraft comes into the vicinity 

creating a potential threat. Operations cannot recommence until the threat is clear. 

C. 14 CFR. § 91.119: Minimum Safe Altitudes 

AC requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that 

prescribes the minimum safe altitudes under which aircraft may operate: 

 Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius 

of 2,000 feet of the aircraft. 

 Over other than congested areas at an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

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." 

To provide the intended operations, the sUAS is normally operated below 400 feet AGL. 

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral 

distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and 

from people not associated with the operation. 

Equivalent Level of Safety 

Compared to flight normal aircraft, AC’s multi-rotor aircraft weigh a maximum of 25 pounds, 

and given the lack of flammable fuel, 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 UAS, as well as the location where it is 

operated. As set forth in the FAA, NTSB, and AFS-80 best practices, the sUAS will be operated in 

a sterile area, where buildings and people will not be exposed to operations without their preobtained consent. Because of the advance notice to the property owners and participants, all 

affected individuals will be well aware of the planned flight operations prior to commencement 

of operations. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that 

are subject to the minimum safe altitude regulations. Finally, the successful safety record of the 

DJI sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer 

operating environments. 
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D. 14 C.F.R. § 91.121: Altimeter Settings 

AC seeks an exemption from 14 CFR 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 because the sUAS 

does not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in the FAA, 

NTSB, and AFS-80 best practices. AC will confirm the altitude of the launch site shown on the 

GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to 

constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. 

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

AC requests an exemption from 14 CFR § 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 –

i. During the day, to fly after that for at least 25 minutes; or 

ii. At night, to fly after that for at least 45 minutes. 

The batteries powering AC’s UAS’s provide approximately 10-25 minutes of powered flight. To 

meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be 

conducted. Given the limitations on the sUAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a safety margin based on a reserve amount 

of battery life is needed. AC will not be conducting any sUAS flights at night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to terminate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the sUAS safely to its planned landing zone from anywhere in its confined area of 

operation even in the event of an unexpected occurrence. Operation of the sUAS with less than 

30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the small UAS, and the proximity of the flight 

operation to the landing zone. Moreover, operation will be limited to controlled areas where 

only people and property owners, or official representatives who have signed waivers will be 

allowed. 

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections 

AC also seeks an exemption from the maintenance inspection requirements contained in 14 
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ACExemptionRequest August 10, 2015 9

CFR 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 CFR Part 43. 14 CFR 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 to these regulations is needed because 

Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the 

sUAS 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 FAA, NTSB, and AFS-80 best practices. The operator will ensure 

that the sUAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. The operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during daylight 

hours, creates less risk than that associated with conventional rotorcraft performing the same 

operation. 

G. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 

333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than 

a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

Equivalent Level of Safety 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the 

Manual’s requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and property owners than 
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ACExemptionRequest August 10, 2015 10

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

H. 14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

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 2 inches nor more than 6 inches high, the 

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

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

Equivalent Level of Safety 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the 

identification of the UAS as “Experimental.” The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

VI. PUBLIC INTEREST 

Granting Airborne Cams an exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those propose in this petition. The one vision of AC is to help facilitate 

safe integration of sUAS’s into mainstream USA in the following areas: 

• Movies and Videography

 Whether the shot requires unique views and expansive panning or extreme altitude 

with radical views, the UAS is designed to hold up under demanding conditions. 

Because of the autopilot feature with pre-designed mission management and R/C 

control interrupt, the pilot and camera operator can easily create the ultimate shot 

with HD video or HD still photos. When working close in on a closed set the hazards 

to the actors are greatly reduced due to the size of the sUAS. 

• News Gathering

 Similar to movies and videography, each news assignment may require a completely 

different shot or view of a scene. With budgets for traditional helicopter use being 

greatly reduced, the UAS is the perfect solution to allow for easy news gathering for 
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a fraction of the cost. The sUAS can and will be operated in a sterile area away from 

the public, while the traditional helicopter must hover over persons and property 

increasing the danger to individuals. 

• Real Estate

 The sUAS can be used in all areas of real estate, including commercial, residential 

and industrial properties. Using a sUAS, real estate professionals can create 

promotional videos, photos and unique shots that normal camera aspects cannot 

capture. AC’s easy-to-use video and photo platform enables properties to stand out,

providing dazzling views that are typically shown via expensive computer animation 

or costly helicopter rentals. Imagine shooting a view from a high-rise condo in 

stunning high definition that shows your potential customer the actual view from 

the residence. The remote platform is great for new planning, zoning and large 

developments. Simple and easy-to-use video and photos allow for multiple height 

pictures and elevation views. 

VII. Privacy 

Airborne Cams is deeply committed to protecting public privacy. AC knows that many individual 

have concerns about privacy from the operations of sUAS’s. AC has created a privacy notice 

that informs residents, commercial property owners, churches, schools, and governmental 

organizations of our intent to conduct commercial drone operations in proximity to their 

property. 

VIII. Federal Registry Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Airborne Cams seeks an exemption from the following rules:

14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 

CFR § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). 

Approval of this exemption request allows AC to conduct commercial operations with small and 

lightweight unmanned aerial systems. AC’s singular vision is to enhance safety of sUAS 

operations in the NAS while reducing risk to the general public and property owners. 

The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all of 

that risk given the reduced mass and lack of combustible fuel carried on bard. The sUAS is 

transported to the designated mission area and set up there. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operation of this small UAS will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the requirements 

of several regulations and allowing commercial operations. These lightweight sUAS’s operate at 

slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer 
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than conventional aerial survey and inspection operations conducted with fixed wing aircraft or 

helicopters. 

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned at: 

With Best Regards, 

Ari Cheren, owner

Airborne Cams, LLC

Office: (310) 948-3042

Email: acheren@gmail.com

IX. Conclusion 

For the foregoing reasons, it is requested that the regulatory exemptions requested herein be 

respectfully granted, and the Petitioner be permitted to conduct small UAS operations 

aforementioned purposes.