September 17,2015

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam: 

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

CFR Part 11; ProArts Media, owner of Small Unmanned Aircraft Systems (UAS), request to be 

exempted from the Federal Aviation Regulations (FAR) listed below so that ProArts Media may 

operate our UAS commercially in airspace regulated by the FAA., as long as such operations 

are conducted within and under the conditions outlined herein or as maybe established by the 

FAA as required by Section 333. 

ProArts Media is a marketing company that specializes in videography and photography based 

out of Chambersburg, Pennsylvania. We have been in operation since 1989 providing these

professional services to local, regional, and national based clients.

The UAS we currently operate with is a DJI Phantom 3 Professional. It’s primary uses are for 

video and photo capturing as per contracted by clients for such things as real estate listings, 

promotional videos, marketing videos, events, landscape photography, magazine photography, 

etc. We currently have 3 trained operators with several hours of flight research, experience, 

training, with our UAS. As with all of our equipment we ensure we know all aspects of its 

capabilities before using it on a shoot. The 3 operators that would also serve as the observers 

during a video or photography shoot would be Joseph Trace, Doug Huber, and Laura Schale. 

We would be the only 3 of responsibility for the UAS at any point and time. 

It operates at a speed less than 50 knots and has the capability to hover and move in the 

vertical and horizontal plane simultaneously. It has an auto return to launch point when battery 

power is under 25%. The UAS will operate within the line of sight with in a protected flight area 

as described below and at 200 feet AGL or less with an observer located close at hand as to 

make voice communication possible. These operations will not create a hazard to users of the 

nation airspace, public nor the environment. 
																																																															

ProArts Media respectfully request the grant of an exception to the following specific sections of 

the Title 14 Code of Federal regulations allowing it to operate lightweight UAS for commercial 

use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 

91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b). 

ProArts Media submits this application in accordance with the Reform Act,112 P.L. 95 331-334, 

seeking relief from any currently applicable FAR'S operating to prevent ProArts Media future 

commercial use of small UAS to operate in the national airspace system as described below. 

The reform Act section 332 provides for such integration of civil unmanned aircraft into our 

national airspace system as it is in the public's interest to do so. Please review the specifications 

of our UAS to see that it does meet the requirements of the exemption as listed below. 

DJI Phantom 3 Professional weighs less than 55 lbs. and operates at speeds less than 50 knots 

and has the capability to operate in the vertical and horizontal plane simultaneously. The UAS 

will operate only within the line of sight of the operator within a protected flight area and at 200 

feet AGL or less. The DJI Phantom 3 Professional has a built in GPS enabled feature allowing 

advanced control options including a “Home” button for ease of landing but most importantly 

incredible control while in flight with very little instability. These will not present a hazard to the 

national airspace nor the public.

The very small nature of these UAS combined with the safe guards presented below, will allow 

for the safe operation greater than that envisioned by Congress for the FAA to establish and by 

exemption allow commercial operations of UAS to commence immediately. Also due to the size 

of UAS and the areas and altitudes they will operate approval of this exception presents no 

national security issues and absolutely minimal safety concerns which have been mitigated 

through our rigorous risk management process. Given the clear direction given in Section 333 of 

the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong 

equivalent level of enhanced safety, reduced emissions utilizing UAS verses traditional aircraft 

as well as the economic impact of greatly reducing the cost of aerial photography thereby 

benefiting the greater public's interest. Accordingly, the applicant requests that the FAA grant 

the requested exemption without delay. 

The following will be incorporated to the Standard Operating Procedures and committed to 

ProArts Media in use with our UAS. 

1. Flights will only occur during the day time hours

2. Flights will be operated in the line of sight of the operator and observer

3. Flights will be terminated at any time variables are presented that determine unsafe flight 

conditions

4. The UAS will weigh less than 55 lbs.

5. Flights will be operated at 200 feet AGL or less.
																																																															

6. Crew will always contain a minimum of an operator and an observer and/or camera 

operator

7. Operator and crew will remain in contact during the flight operation,

8. The UAS operator will perform a check of the flight area for all structures, persons, 

animals, vehicles and other objects for stability and safety prior to flight.

9. Consent will be obtained from all persons with in the video capabilities of the units to 

further reduce the chance of violating anyone's privacy.

10. All required FAA clearances will be obtained and required distances from airports strictly 

observed by operator. Locations will also be checked prior to any scheduled shoot to 

check distance from any known FAA regulated airspace.

11. “Return Home” Feature will be checked prior to flight to ensure safety during shoot in 

case of low battery or emergency landing deemed by manufacturer setting. 

12. Our UAS has a display function on the control to tell operator the measurements of 

distance of height from the operator to ensure it stays within FAA regulated limits. To be 

noted that the operated may also set a maximum distance perimeter, which is a feature 

of the DJI GO mobile application we use where the UAS will stop automatically once it 

has reached the maximum distance set. 

13. The operator and observer will be in constant communication during active flight. 

14. ProArts Media obtains all consent from all clients, owners, property owners, personnel, 

or alike prior to any video or photography shoot. 

We appreciate the time taken to read our exception request. We will provide any additional need 

information, data, or documentation at your request. 

Please Contact:

ProArts Media

C/O Joseph Trace

197 Falling Spring Road 

Chambersburg, PA 17202