Original 10/20/2015 Page 1

October 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform 

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Dear Sir or Madam,

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

Act) and 14 C.F.R. Part 11, Silver Screen Tele-Reality, Inc. ( Silver Screen ) hereby 

files this petition to commercially operate DJI Phantom III Professional Unmanned 

Aircraft System (UAS).

The requested exemption would support an application for a commercial Certificate of 

Authorization (COA) to utilize the DJI Phantom III (Phantom) to offer Aerial 

Photography and Videography services for appropriate commercial applications.

A few examples of such industries include, but not limited to, are automobile 

dealerships, automotive industry, real estate properties, construction site surveys, 

structure inspections, and other potential industries that need aerial data collection.

The Phantom UAS consists of a lightweight (4 lb) battery operated quadcopter 

unmanned aircraft, onboard camera, and associated communications equipment.

The Phantom Unmanned Aircraft (UA) has previously demonstrated to have 

successfully met the safety and operational requirements resulting in previous grants of 

section 333 exemption requests by other commercial UAS operators.

Silver Screen Tele-Reality, Inc., offers marketing and videography services, specializing 

in automobile dealerships. The intended operation of Phantom UAS will enhance the 

services utilizing aerial photographs and videos for our customers.

The Phantom UA carries an onboard high resolution camera system that allows it to 

perform aerial photography, and videography.

By granting the exemption, Silver Screen’s UAS operations will create benefits to both 

the economy and the environment which are ultimately in the public interest.

The aircraft will be operated in accordance with the conditions and limitations set forth 

in the grant and the following applicable restrictions:
Original 10/20/2015 Page 2

- All operations will occur at no more than 200' above ground level (AGL)

- The aircraft will be operated with the permission of the property owner

- When necessary, applicable permits will be acquired from local authorities

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC at all time

- While the aircraft is airborne, the VO will be able to communicate verbally with the PIC

- When necessary and applicable, Silver Screen will file a NOTAM providing 

radial/DME, radius, and a date/time group for each operation

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time

For certain complex operations, Silver Screen may assign sensor or software 

application operators to assist the operations. 

We submit that the combination of ;

- Phantom UA’s light weight and historically demonstrated safe operation and receiving 

approvals of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operations under the guidelines established within the grant,

the FAA can have confidence that Silver Screen’s UAS operations will have an 

equivalent or greater level of safety of manned aircraft performing the same mission.

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Additional documents supporting this petition will be 

submitted following this request. 

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Israel Alpert

CEO

Silver Screen Tele-Reality, Inc.

4144 N. Central Expy,

Ste 710

Dallas, TX 75204

Tel: (972) 855-3500

Fax: (413) 778-2146

Email: oalpert@sister.tv

cc: Bryan Archer

 bryan@galaxymro.com
Original 10/20/2015 Page 3

TABLE OF CONTENTS

NAME, ADDRESS, AND CONTACT INFORMATION OF PETITIONER .............Page 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SILVER SCREEN 

SEEKS EXEMPTION...................................................................................................Page 4

THE EXTENT OF RELIEF SILVER SCREEN SEEKS AND THE REASONS

SILVER SCREEN SEEKS THE RELIEF ............................................................... Pages 4 to 6

THE REASONS WHY GRANTING SILVER SCREEN’S REQUEST WOULD

BE IN THE PUBLIC INTEREST .............................................................................. Page 7

THE REASONS WHY GRANTING SILVER SCREEN THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY ........................................................................ Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT SILVER SCREEN’S REQUEST............................. Pages 10 & 11

ACRONYMS.............................................................................. Pages 11 & 12
Original 10/20/2015 Page 4

NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER 

Israel Alpert

CEO

Silver Screen Tele-Reality, Inc.

4144 N. Central Expy,

Ste 710

Dallas, TX 75204

Tel: (972) 855-3500

Fax: (413) 778-2146 

Email: oalpert@sister.tv

cc: bryan@galaxymro.com

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF SILVER SCREEN SEEKS AND THE REASONS SILVER 

SCREEN SEEKS THE RELIEF 

14 CFR 61.113 Private pilot privileges and limitations: 

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot 

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private 

pilot to act as pilot in command of an aircraft in connection with any business or 

employment if;

(1) flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

Since the aircraft cannot carry passengers or property, we request to be relieved from 

this regulation if our pilots at minimum, 

(1) hold at least a current sport pilot certificate and,

(2) hold a driver license or a third class medical certificate.

By meeting conditions (1) and (2), we believe that equivalent level of safety can be 

achieved by complying with 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 91.7 (a) states,

“No person may operate a civil aircraft unless it is in an airworthy condition.”

This rule prohibits the operation of an aircraft without an airworthiness certificate. 

Since there is no such existing certificate that is applicable for the Phantom UAS to 

properly comply with the FARs, we request that Silver Screen to be relieved from this 
Original 10/20/2015 Page 5

regulation.

To provide equivalent level of safety, we will ensure that the Phantom UAS is in 

airworthy condition prior to every flight by following necessary safety procedures. 

14 CFR 91.119 Minimum safe altitudes: General 

This regulation provides that over sparsely populated areas the aircraft cannot be 

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

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this 

requirement.

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of 

flight and the associated risks to persons and property on the ground. We maintain that 

due to the small size of the Phantom, the hazard to persons, vessels, vehicles, and 

structures is not comparable to manned aircraft and should be considered in granting 

the exemption. 

14 CFR 91.121 Altimeter Settings 

This regulation provides that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 nautical miles of the aircraft. 

The Phantom aircraft will fly below 400 feet AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft.

 

To provide an equivalent level of safety, the PIC will check and confirm the Phantom’s 

GPS altitude read out before each flight.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing 

and to fly after that for at least 30 minutes. We believe the intention of this rule is to 

provide a reserve of energy as a safety buffer for go-arounds and other delays to 

landing.

The Phantom UAS is battery operated and the maximum duration of flight with full 

payload, from a single battery charge is approximately 23 minutes. 

We believe that equivalent level of safety can be achieved by limiting our flight time to 

20 minutes with reserve energy for 3 minutes on the battery.
Original 10/20/2015 Page 6

14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be " approved for return to service by a 

person authorized under 43.7 " after maintenance and inspection. It is our intention 

that the PIC, VO or authorized personnel to perform maintenance and inspection of the 

aircraft and "be authorized to approve the aircraft for return to service."

Silver Screen requests that exemptions to the regulations under conditions below;

(1) Silver Screen will follow Phantom’s manufacturer maintenance instructions, 

techniques and procedures 

(2) To ensure equivalent level of safety, PIC will inspect the UA before each flight 

looking for any structural or mechanical malfunctions

Due to the small size, light weight and simplicity of the Phantom UAS, we believe that 

the equivalent safety will be achieved by permitting any of the PIC, VO or authorized 

personnel, to perform maintenance, inspection and alterations of the aircraft and " be 

authorized to approve the aircraft for return to service. "
Original 10/20/2015 Page 7

THE REASONS WHY GRANTING SILVER SCREEN ’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR 61.113, 61.133

14 CFR 91.9, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and 

will benefit the public as a whole for the following reasons.

1- The Phantom III UA is battery operated and free from the harmful emissions 

associated with the manned aircraft that are currently used for aerial photography 

and videography.

As recently proven by several grants of section 333 petitions, UASs offer 

equivalent level of safety while reducing environmental impacts, which is in the 

public interest.

2- Silver Screen’s UAS operations will contribute to a positive aggregate 

economic impact resulting in creation of jobs both direct and indirectly. 

Economic Research estimates that the UAS market will grow from $ 6 billion to

$ 82 billion over the next decade resulting in a new workforce development. 

Because Silver Screen’s operations will create new jobs such as pilots, flight 

operation staff, and administrative supporting staff, it will directly cause positive 

economic impact, hence granting Silver Screen’s petition will benefit the public 

as a whole.

3- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS(s) into the national airspace system, hence the passing 

of the FAA Modernization and Reform Act of 2012. 

Granting Silver Screen’s petition furthers the public interest as a demonstrated 

progression of integrating Unmanned Aircraft Systems into National Air Space, 

thus it will benefit public as a whole. 
Original 10/20/2015 Page 8

THE REASONS WHY GRANTING SILVER SCREEN THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY

Silver Screen believes that the grant of exemption from, 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of reasons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF SILVER 

SCREEN SEEKS AND THE REASONS SILVER SCREEN SEEKS THE 

RELIEF ” by describing how we intend to mitigate risk and accomplish FAA 

equivalent and acceptable level of safety for each 14 CFR part.

 

(b) As a result of Phantom unmanned aircraft’s size, weight, speed, operational 

capability, proximity to airports and populated areas, operation within visual line 

of sight combined with the implementing FAA required safety procedures, we 

believe that granting Silver Screen’s exemption request will not adversely affect 

safety.

(c) DJI Phantom III has demonstrated to satisfy necessary safety risk mitigation by 

FAA thus resulting in multiple grants of section 333 petitions.

Because of the combination of Phantom’s proven success and the conditions 

and limitations of our operations, we believe granting Silver Screen’s request will 

not adversely affect safety. 
Original 10/20/2015 Page 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Silver Screen Tele-Reality, Inc.

Petition of exemption from sections of ;

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

Silver Screen seeks FAA Regulatory exemption for commercial operation of the 

Phantom III unmanned aircraft manufactured by DJI Co, Ltd. of China. 

The Phantom unmanned aircraft system has an onboard camera system capable of 

acquiring high resolution data.

Proposed operations will offer aerial photography and videography services for

appropriate commercial industries.
Original 10/20/2015 Page 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT SILVER SCREEN’S REQUEST

 DJI Phantom III Unmanned Aircraft System 

 General Features

 Ready to Fly, Multifunctional Quad-rotor System

 Customized H3-2D and H3-3D Gimbal Support

 Precision Flight and Stable Hovering

 25 min Flight Time & Smart Battery

 Auto Return-to-Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement

 Self-tightening Propeller

 Video Downlink Support

 CAN-Bus Expansion Module

 Control Link radio operating frequency 2.4 GHz ISM

 Operating Distance 1 mile

Aircraft Performance

Empty Weight 2.8 lbs

Max Take-off Weight 4 lbs

Max Flight Speed 30 Knots

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 3 m/s

Diagonal Length 350mm

Flight Time 25 minutes

 DJI Phantom 3 Professional User Manual

Silver Screen will utilize the DJI phantom 3’s user manual which can be found online at 

the link below.

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.

4_en_0915.pdf
Original 10/20/2015 Page 11

Flight Safety Resources

Silver Screen will utilize the resources provided by the organizations and their websites 

at the links listed below.

FAA UAS Resources

http://www.faa.gov/uas/

http://knowbeforeyoufly.org/

AMA Safety Code

http://www.modelaircraft.org/files/105.pdf

No Privacy Issues

Silver Screen’s proposed operations will create no privacy issues because the 

Phantom UAS will be operating in the areas within the boundaries of the properties with 

the land owner’s permission. 

When necessary and required, Silver Screen will also obtain any permits or 

authorizations from local authorities.

ACRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point
Original 10/20/2015 Page 12

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FARs Federal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management 

System

FTP Flight Termination Point

FTS Flight Termination System

Crosstimbers Silver Screen Tele-Reality, Inc.

GHz Gigahertz

GCS Ground Control Station

MHz Megahertz

MTOW Maximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

NOTAM Notice To Airman 

OPA Optionally Piloted Aircraft

PIC Pilot in Command

Phantom Phantom Unmanned Aircraft System

Phantom Phantom Unmanned Aircraft

R&D Research and Development

RF Radio Frequency

RM Risk Management

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System(s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer