Dennis Bernhard

2020 NE 56th St

Apt 201

Ft. Lauderdale, FL 33308

954-551-2951

May 31, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 

61.113 (a) & (b); 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) (2);91.417 (a) & 

(b).

To Whom It May Concern:

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

14 C.F.R. Part 11, Dennis Bernhard, hereafter referred to as "Petitioner", would 

like to apply for an exemption from the following Code of Federal Regulations

(C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft 

Systems (UAS) for aerial imaging and video in the South Florida (Monroe, MiamiDade, Broward and Palm Beach Counties) and surrounding areas.

Public Good

Aerial photography/videography for Film/Television, fine art, and geographical 

awareness for real estate and golf course marketing and has been around for a 

long time through manned fixed wing aircraft and helicopters. But for small 

business owners, its expense has been cost-prohibitive. Granting this exemption 

would allow the Petitioner to provide this service at a much lower cost. Further, 

the small UAS’s being utilized in this application will pose no threat to the public 

given its small size and lack of combustible fuel when compared to larger 

manned aircraft. The operation of the UAS’s will minimize ecological damage and 

promote economic growth by providing information to businesses & individuals in 

the South Florida (Monroe, Miami-Dade, Broward and Palm Beach Counties) and 

surrounding Area.

The Petitioner has experience in flying the DJI Phantom3 for recreational

purposes as well as the use of Flight Training software during the past year

without incident.

The Petitioner will abide by all FAA requirements to ensure this exemption will 
provide a level of safety at least equal to existing rules and will only operate in a 

safe environment that is strictly controlled. The Petitioner’s exemption request 

would permit operation of ultra-light weight, unmanned (piloted by remote control) 

in predetermined areas away from general public, airports, heliports and 

vehicular traffic, under 400 feet AGL, during daylight hours and after carefully 

reviewing, inspecting and examining the area of aerial observation. The 

Petitioner will conduct extensive preflight inspections and protocols, during which 

safety carries primary importance. This would allow for videos and photos within 

property boundaries for individual homeowner real estate listings.

Approval of this exemption would thereby enhance safety and fulfill 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." Section 333(c) of the Reform Act. Information Supporting this 

Petition as Specified in 14 C.F.R. §11.81

(a) Your name and mailing address and, if you wish, other contact information 

such as a fax number, telephone number, or e-mail address;

Dennis Bernhard

2020 NE 56th St

Apt 201

Ft. Lauderdale, FL 33308

(954) 551-2951

Email: dennis@brownchairphotography.com

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

(b) The specific section or sections of 14 C.F.R. from which The Petitioner seeks 

an exemption

• 21- Subpart H Certification procedures for products and parts, Airworthiness

Certificates

• 45.23 - Display of marks; general

• 61.113- Private pilot privileges and limitations: Pilot in command

• 91.103- Preflight Actions

• 91.105- Flight crew members at stations

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests.

• 91.119- Minimum safe altitudes: General

• 91.121-Altimeter settings

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

• 91.203 -Civil aircraft: certification required

• 91.405- Maintenance required

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, 

and alteration

• 91.409 -Inspections

• 91.417 - Maintenance records
(c) The extent of relief The Petitioner seeks, and the reason The Petitioner seeks 

the relief The Petitioner seeks an exemption for several provisions of 14 C.F.R. 

Parts 21, 45, 61, and 91 to the extent to operate small UASs to record aerial 

video for cinematographic purposes.

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS or the public or pose a threat to 

national security in light of the following:

• 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 visual line of sight of the operator.

Reform Act§ 333 (a). Lastly, 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"

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, that includes sUASs, from the 

requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702-

44716 of this title if the Administrator finds the exemption in the public interest. 49 

U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC§44704; 14CFR§91.203 

(a) (1).

14 C.F .R. 21 - Subpart H Certification procedures for products and parts,

Airworthiness Certificates

The Petitioner seeks exemption from 14 C.F.R. 21, Subpart H which states the 

certification procedures for products and parts as well as airworthiness 

certificates. 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, television production and Real Estate, provide a 

greater degree of safety to the public and property owners than 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.

The Petitioner has studied the manufactures best practices and manuals to 

promote and provide safe flying experiences for the PIC. 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.

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

The Petitioner seeks exemption from 14 C.F.R. 45.23, which discusses the 

display of marks. Specifically, section 45.23 states, "(a) each operator of an 

aircraft must display on that aircraft marks consisting of the Roman capital letter 

"N" (denoting United States registration) followed by the registration number of 

the aircraft. Each suffix letter used in the marks displayed must also be a Roman 

capital letter (b) 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".

The Petitioner will need exemption from this regulation due to the small size of 

the aircraft and that there is no cabin, cockpit, or pilot station for the aircraft. The 

words "Experimental" has been placed on the fuselage in compliance with 

§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.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command. The Petitioner seeks exemption from 14 C.F.R. 61.113, which 

discusses private pilot privileges and limitations for the Pilot in command (PIC).

The Petitioner is seeking exemption from this regulation, because The Petitioner

believes that there is inconclusive evidence that a person with a private pilot 

certificate can successfully maneuver a sUAS without first hand flight experience 

with the particular sUAS. In fact, having a private pilot license does not 

automatically ensure competence at flying an sUAS in 3rd person view as 
required to properly operate an sUAS within the required line of sight. However, 

we believe that the PIC and our FOVO (Field Operation Visual Observer) must 

be able to understand and correctly interact with the general aviation community. 

Therefore, we believe our own flight training with the sUAS will be more than 

satisfactory.

Our PIC (Dennis Bernhard) a professional Photographer/Film maker of more 

than 3yrs has 1 year of Hobby Model Flight experience with the sUAS.

14 C.F.R. 91.103- Preflight Actions

The Petitioner seeks exemption from 14 C.F.R. 91.103 which states that each 

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

available information concerning that flight. This information must include: (a) For 

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; actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data 

before starting a flight.

The Petitioner will be operating our sUAS in VFR. Our operations manual(see 

attached) already includes preflight procedures directly pertaining to our sUAS 

which includes equipment checklist as well a preplanning details regarding 

weather conditions, review of any possible flight path of general aviation, our 

mission flight path and weather conditions amongst other parameters required to 

complete the mission.

14 C.F.R. 91.105 -Flight crewmembers at stations

The Petitioner seeks exemption from 14 C.F.R. 91.105, which discusses flight 

crew members at stations. Specifically, 91.105 states "(a) During takeoff and 

landing, and while en route, each required flight crewmember shall (1) Be at the 

crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological 

needs; and (2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, 

during takeoff and landing, keep his or her shoulder harness fastened while at his 

or her assigned duty station. This paragraph does not apply if (1) The seat at the 

crewmember's station is not equipped with a shoulder harness; or (2) The 

crewmember would be unable to perform required duties with the shoulder

harness fastened. The Petitioner will need exemption from this regulation due to 

the fact that the sUAS will not have a flight crew or crew stations other than the 

PIC. The PIC will also not have to be restrained into a seat via shoulder harness 

or safety belt at the time of the flight.
14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain 

flight tests

The Petitioner seeks exemption from 14 C.F.R. 91.109, which discusses flight 

instruction, simulated instrument flight, and certain flight tests. Specifically, 

91.109 states "(a) No person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. However, instrument flight instruction may be given in 

an airplane that is equipped with a single, functioning throw over control wheel 

that controls the elevator and ailerons, in place of fixed, dual controls, when (1) 

The instructor has determined that the flight can be conducted safely; and (2) 

The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings. (b) An airplane equipped with a single, 

functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls may be used for flight instruction to conduct a

flight review required by §61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.5 7 when (1) The 

airplane is equipped with operable rudder pedals at both pilot stations; (2) The 

pilot manipulating the controls is qualified to serve and serves as pilot in 

command during the entire flight; (3) The instructor is current and qualified to 

serve as pilot in command of the airplane, meets the requirements of §61.195(b), 

and has logged at least 25 hours of pilot-in-command flight time in the make and 

model of airplane; and ( 4) The pilot in command and the instructor have 

determined the flight can be conducted safely. (c) No person may operate a civil 

aircraft in simulated instrument flight unless (1) The other control seat is occupied 

by a safety pilot who possesses at least a private pilot certificate with category 

and class ratings appropriate to the aircraft being flown. (2) The safety pilot has 

adequate vision forward and to each side of the aircraft, or a competent observer 

in the aircraft adequately supplements the vision of the safety pilot; and (3) 

Except in the case of lighterthan-air aircraft, that aircraft is equipped with fully 

functioning dual controls. However, simulated instrument flight may be conducted 

in a single-engine airplane, equipped with a single, functioning, throw over 

control wheel, in place of fixed, dual controls of the elevator and ailerons, when 

(i) The safety pilot has determined that the flight can be conducted safely; and (ii)

The person manipulating the controls has at least a private pilot certificate with

appropriate category and class ratings. (d) No person may operate a civil aircraft

that is being used for a flight test for an airline transport pilot certificate or a class 

or type rating on that certificate, or for a part 121 proficiency flight test, unless the 

pilot seated at the controls, other than the pilot being checked, is fully qualified to 

act as pilot in command of the aircraft". Again, Except when necessary for takeoff 

or landing, no person may operate an aircraft below the following altitudes: (a) 

Anywhere. An altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. (b) Over congested 

areas. 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. (c) Over other than 

congested areas. An altitude of 50Q 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.

(d)Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the surface- (1) 

A helicopter may be operated at less than the minimums prescribed in paragraph 

(b) or (c) of this section, provided each person operating the helicopter complies 

with any routes or altitudes specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less 

than the minimums prescribed in paragraph (c) of this section (a) Each person 

operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when 

operating-(1) Below 18,000 feet MSL, to-(i) The current reported altimeter setting 

of a station along the route and within 100 nautical miles of the aircraft; (ii) If 

there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or (iii) In 

the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure; or (2) At or 

above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is 

determined by the atmospheric pressure in the area of operation as shown in the 

following table:

The Petitioner believes that there is inconclusive evidence that a person with a 

private pilot certificate or license can successfully maneuver or train someone to 

use an sUAS without first hand flight experience with the particular sUAS. Flying 

in 3rd person orientation requires built-up experience in that form of flying for 

many years. Therefore, we believe our own flight training, pilot protocols and first 

hand experiences with the sUAS as laid out in our Flight Operations Manual 

meets and exceeds the requirements necessary to safely operate our sUAS for 

the tasks we purpose. Also, the sUAS will be operated by a remote control, which 

will only require a single person operator and dual controls will not be necessary.

14 C.F.R. 91.119- Minimum safe altitudes: General

The Petitioner seeks exemption from 14 C.F.R. 91.119, which discusses 

minimum safe altitudes. As this exemption is for a sUAS that is a quadcopter and 

the exemption requests authority to operate at altitudes up to 400 AGL, or not 

more than 200 above an elevated platform from which filming is planned, an 

exemption may be needed to allow such operations. As set forth herein, except 

for the limited conditions stated in the Manual, the UAS will never operate at 

higher than 400 AGL. It will however be operated in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. The equivalent level of safety will be achieved 

given the size, weight, speed of the UAS as well as the location where it is 

operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the

planned flight operations as set forth in the Manual. Compared to flight 
operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL in the movie industry. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small- UAS 

operations and the operations of conventional aircraft that must comply with 

Section 91.119.

14 C.F.R. 91.121- Altimeter settings

The Petitioner seeks exemption from 14 C.F.R. 91.121, which discusses 

altimeter settings for lowest usable flight level.

C.F.R. 91121 states,

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the

minimum flight level, the pilot shall take the flight level equivalent of the minimum

altitude in feet and add the appropriate number of feet specified below, according 

to the current reported altimeter setting

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

The Petitioner's sUAS uses both GPS altitude and barometric sensors and relays 

that information to our ground station. However, this data is used help the sUAS 

to automatically maintain position hold at the required elevation and therefore this 

code is not pertinent the functionality of this sUAS.

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR)

conditions

The Petitioner seeks exemption from 14 C.F.R. 91.151, which discusses fuel 

requirements for flight in VFR conditions. Specifically, 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- (1) 

During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after 

that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes".

The Petitioner's sUAS has a typical mission time of less than 10 minutes with 

maximum flight time of 20 minutes. Since this amount less than the 30 minute 

reserve minimum, this reserve minimum would not even make sense in allowing 

the sUAS a chance to fly. According to The Petitioner’s aircraft flight manual, the 

PIC is instructed to maintain flight until battery power reaches 25%, or 1st level 

warning. At this level, landing procedures will be intiated. Once the sUAS reads 

20%, 2nd level warning, the flight control system automatically take over and 

initiates safe landing sequence at the logged in takeoff point. 

The Petitioner believes that an appropriate and current airworthiness certificate 

would not be necessary to fly a sUAS given the size of the aircraft and the 

necessary level of skill needed to operate the aircraft. Before putting in to 

service, each of our sUAS goes through our own airworthiness proceedures of 

miminum test flight and reliability checks. Also, our sUAS are recalibrated each at 

the site location before each flight to ensure that all systems functions as 

designed. The Petitioner seeks exemption from this regulation because we 

believe this rule was not meant for a sUAS and operators.

14 C.F.R. 91.405, 91.407, 91.409, and 91.417

The Petitioner seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 

91.417, which discusses required aircraft maintenance, operation after 

maintenance, preventive maintenance, rebuilding, or alteration, inspections, and 

maintenance records. The Petitioner believes these regulations are meant for 

manned operated aircrafts and not unmanned systems, therefore making them 

unnecessary. Nevertheless, we seek an exemption from any such specific 

provisions to the extent FAA finds it necessary to grant this request.

(d) The reasons why granting The Petitioner's request would be in the public 

interest; that is, how it would benefit the public as a whole.

The Petitioner is seeking to build a business that provides aerial support for 

commercial interest. The Petitioner's use of a sUAS can assist in making task 

safer and minimize human exposure to being at dangerous elevations. The 

Petitioner's sUAS usage in the aerial photography and cinematography will also 

reduce the time required to captured the needed scenes as compared to 

convention helicopters or airplanes. Ultimately, the result is quick completion of 

task an reduction of dangerous elevation perspective needs.
(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided 

by the rule from which The Petitioner seeks exemption will provide a level of

safety that exceeds the level of safety required by the FAA for its use on sUAS. 

The following are The Petitioner's safety procedures, features, regulations, and 

operating specifications for our sUAS:

• The Chief Pilot in Charge is professional film maker of 3yrs who has 1 year of 

flight experience in Multi-Rotor 3rd person flight.

• The Pilot In Command (PIC) will be required to wear hard hats, safety vests, 

and safety glasses to protect the head and eyes from potential mishaps during 

given operational flights including training or testing of sUAS.

• The flight area of the sUAS will be observed for best take off and landing 

locations. Desired conditions include: flat and level surfaces clear of debris, at 

least 15ft from power lines and structures, and a minimum distance of 12ft from 

the PIC and observers.

• The sUAS will also be in the Visual Line of Sight (VLOS) to the PIC during all 

flights.

• Flights must take place during good weather conditions with no rain, low laying

clouds, or heavy winds. All flights will take place during daylight hours with no 

evening or late night flights.

• All batteries must be charged completely before each flight and each flight must 

end when the battery has a 30% power level remaining.

• A visual safety inspection will occur before each flight, testing propeller 

tightness, security mount of camera/detection equipment, remote range test, and 

proper safety equipment is adorned to PIC.

• The sUAS will be flown under a height of 500 ft AGL.

• The PIC will not engage in, nor may a PIC permit, any activity during a

critical phase of flight so as to ensure that the sUAS is in a condition for safe 

flight operation and in a configuration appropriate for the purpose of the intended 

flight.

• If there is more than just an operator at a site during a flight, the PIC operator 

and will maintain two-way communication with each other during all

operations; if unable to maintain two-way communications, or if any condition 

occurs that may otherwise cause the operation to be unsafe, the operator will 

immediately conclude the operation.
• If the communication link is lost, the sUAS will go into fail-safe mode and safely

descend to its designated home-point location. If the communication link is

reconnected during fail-safe mode, control of the sUAS can be regained before

landing occurs at the home-point location.

• There is no fuel or payload to the sUAS, therefore there will be no potential

explosives or risk of explosion if a crash occurs with the sUAS.

• The sUAS will feature a built in compass that will be recalibrated at every site to

maintain accurate directional readings. The compass will also help in keeping the

sUAS stable during flights.

•The sUAS will record GPS location data once Ready to Fly status has been 

obtained.

•A minimum of 6 satellites will activate the Ready to Fly status.

•The weight of the sUAS is less than 15 lbs .

•The aircrafts vertical and horizontal aspect concerning hovering accuracy is less 

than 0.5m and 1.5m respectfully. With a maximum wind resistance of 18mph.

•The typical aircraft wheelbase will be less than 1OOOmm in length.

•The aircraft runs off a Li-Po battery.

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The 

rule from which you seek the exemption; and (2) A brief description of the nature 

of the exemption you seek

Petitioner: Dennis Bernhard

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 

91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 

91.407; 91.409; and 91.417

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 

C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c);

91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to

Cinematographic filming subject to operating procedures that meet or exceed 

those that FAA requires.

(g) Any additional information, views or arguments available to support your 

request Please see the introduction to this exemption request.

(h) If you want to exercise the privileges of your exemption outside of the United
States, the reason why you need to do so.

The Operations described in this exemption request will be conducted wholly 

within the United States.

Please do not hesitate to contact me via email at 

Dennis@brownchairphotography.com if you have any questions

Very truly yours,

Dennis Bernhard