HiRez Productions, LLC 

1101 S. State Street Apt 2202

Chicago, IL 60605 

P: 312.735.0768

E: Michael@HiRezProductions.com

W: HiRezProductions.com 

December 16th, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE Washington, DC 20590

RE: Request for Exemption Per PL 112-95 § 333 from 14 CFR Part 21, 14 CFR 45.23 (b), 14 

CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 

CFR 91.151(a), 14 CFR 203 (a) & (b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 

91.417(a) and (b)

To Whom It May Concern,

This letter will serve as a request for an exemption of the above sections of title 14 CFR for HiRez 

Productions, LLC, henceforth referred to as the “Petitioner,” for the purpose of conducting 

commercial aerial photography, videography, home inspections, and survey operations using a 

small Unmanned Aircraft System (sUAS) in FAA controlled airspace. As described herein, the 

Petitioner has staff who are experienced in the operation of UAS, including but not limited to use 

of multi-rotor sUAS, flying multicopters of varying sizes under 55 pounds using both Visual Line 

Of Sight (VLOS) and on board camera controls. The following petition provides all of the 

necessary information to justify an exemption from the above listed Federal Aviation Regulations. 

The Unmanned Aircraft System 

The Petitioner will be operating a DJI Phantom II. The Petitioner may add additional 

airframes to their inventory as required from the DJI or other lines. The Petitioner will operate the 

airframe within its design parameters. 

The sUAS has built in functionality that can limit the height it flies above the ground and 

restrict

sUAS from flying in class B,C, and D airspace. The aircraft also comes preinstalled with the ability 

to automatically return to the pilot in control and land if any of the previous restrictions are 

violated, or if the connection to the wireless controller is lost. 

The sUAS weighs 2935 grams (just under 6 pounds) while carrying all necessary 

batteries and cameras. It also has a max speed of 22 meters per second (just under 43 knots) 

that can be limited prior to takeoff. 

The Unmanned Aircraft PIC

The company senior operator and initial PIC Michael Himes is an experienced operator. 

Mr. Himes has over 100 hours of sUAS in recreational flights. HiRez Productions, LLC, will keep 
logged hours of training events and duration of flight operations. New PICs will have a minimum 

of 5 actual flight hours (15 Flights ) before being allowed to operate sUAVs. 

sUAS Operation Overview 

The sUAS will be operated to provide aerial photography, videography, and survey 

services to the public sector, particularly for the purposes of real estate, weddings, events, 

property inspection, and property surveys. 

Prior to the operation, flight restrictions will be programmed into the sUAS to prevent it 

from flying more than 400 feet above ground level. Before takeoff, the operator and observer will 

review the pre-flight checklist and survey the area to determine if weather/cloud conditions are 

suitable for flight and what the emergency landing sites would be. Once the operations are 

complete, the sUAS will be inspected to determine if any maintenance will be needed before the 

next operation. 

Compared to traditional flights using manned aircraft, flights using sUAS are much less 

dangerous and therefore would not adversely affect safety: 

 The nature of these flights will restrict the use of the sUAS to a small area where all 

nearby persons can be aware of ongoing flight

 The sUAS carries no explosive materials or combustible liquid fuel

 The light weight of the sUAS would cause minimal damage in the event of an airborne 

failure, especially when compared to traditional manned aircraft with airworthiness 

certificates

 The small size of the sUAS would allow for all operations to be conducted within a clearly 

defined area, including takeoffs and landings. 

All flights by the PIC will begin and remain outside of a 5 nautical miles radius of any 

airport having an operational control tower, 3 nautical miles from an airport with a published 

instrument flight procedure but not an operational tower, 2 nautical miles from an airport without a 

published instrument flight procedure or an operational tower and 2 nautical miles from a heliport 

with a published instrument flight procedure. The sUAS has a mandatory, built-in functionality to 

restrict the aircraft from flying within this radius and will automatically land if it inadvertently 

violates this restriction. Any and all precautions will be taken by the PIC and the accompanying 

observer to prevent midair collisions with objects and other aircraft, even outside the 5 nautical 

mile radius of airports. 

All planned operations utilizing the sUAS will be completed safely. With the combination 

of the preflight safety risk assessments previously discussed and the inherently reduced risk of 

flying a sUAS compared to a traditional manned aircraft, the PIC will be able to provide a level of 

safety greater than the traditional method of performing aerial based photography, videography, 

and survey operations. 

Benefit to Public Interest 

The services provided by the Petitioner would be a great benefit to the public as a whole. 

Granting this exemption would reduce the need for traditional forms of aerial photography, 

videography, inspections, and surveys which, as previously discussed, are much more dangerous 

than operations performed by sUAS. The cost of services of sUAS operations is also significantly 

lower than traditional aerial photography flights, making these services available to smaller 

businesses or individuals that otherwise may not be able to afford them. This in turn, allows 

businesses to better serve their clients, increasing the public benefit as a whole. 
Conclusion 

All commercial sUAS flights by the Petitioner shall satisfy the criteria provided in Section 

333 of the Reform Act of 2012, including: size, weight, speed, flight within VLOS, distance from 

PIC, distance from airports, operation capabilities, maintaining safety, and the benefit to the 

public. These qualifications more than justify granting the Petitioner, HiRez Productions, LLC, 

with an exemption to the stated sections of title 14 CFR. 

The requests of this Petition are similar to those of Marcus D. Melhus, Ralph J. Apel, 

Saratoga Aerial and Video, and Cornerstone Technology Services, all of whom have received 

Section 333 exemptions for use of comparable aircraft for similar operations. 

Thank you for your time and consideration. 

Sincerely, 

Michael C. Himes 

Founder/President 

HiRez Productions, LLC