Mason Geiger 

Photography & Film, LLC

3829 S State Road 15

Warsaw, IN 46580

574.306.4410

mason@masongeigerfilm.com

July 15, 2015 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act 

To Whom It May Concern,

This document is hereby an Exemption Request following Section 333 of the FAA 

Modernization and Reform Act of 2012. That Aviation Unmanned be utilized for the 

purposes of Aerial Photography by Mason Geiger Photography and Film, LLC. The 

primary function of this UAS would be to acquire aerial video and still imagery for 

clientele requiring such services. The specific UAS to be utilized for these services is the 

DJI Inspire 1. 

The exemption status would condone Mason Geiger Photography & Film, LLC to pursue 

aerial services in a professional means for servicing commercial clientele using a small 

UAS in the following areas: 

• Real Estate Photography 

• Industrial Surveying 

• Special Events 

Code of Federal Regulations by which the exemption is at request: 

14 C.F.R. Part 21, Subpart H 

14 C.F.R. 45.23 

14 C.F.R. 91.7(a), 91.9(b), 91.109, 91.119, 91.121 

14 C.F.R. 91.151(a), 91.203(a)(b), 91.401-91.417 
Unmanned Aircraft System 

Mason Geiger Photography & Film, LLC is equipped with a DJI Inspire 1. The practical 

use of this UAS outweighs and is viewed superior to that of helicopters for the purpose of 

gathering aerial and video and photography. This UAS follows protocol by operating 

under these safety qualities: Four (4) blade quadcopter weighing 6 pounds, 7.5 ounces 

with a maximum airspeed of 30 knots. Controller operates on frequencies of 

5.728-5.850GHZ / 2.400-2.483GHZ with a built-in ground support technology that 

allows it to fly utilizing GPS for stability, tracking, safe flight mode and return to home 

feature in the event of loss of remote control signal or critical low battery. 

All flights start with a pre-flight safety check and all flight data is recorded. The Inspire 1 

is equipped with a fixed position camera that sends a live video signal to the controller 

allowing the PIC (person in control) to monitor real time video. Flight data, speed height, 

distance, battery level, and general aircraft conditions are also displayed during 

operations. The Inspire 1 battery has a flight time of 18 minutes and is therefore always 

returned to original take off point and is always flown utilizing VLOS.

UAS safety specifications in relation to the Model Aircraft Operating Standards: 

1. UAS will operate solely in line-of-sight of its’ pilot and within sufficient distance of 

populated areas within the sterile area according to the FOPM. Flights are 

oriented such that the PIC (pilot in control) has full visual contact of the UAS 

rear-mounted LED flight indicators. 

2. Airport command will be notified immediately in the case of UAS flight within 

three (3) miles of any airport, and will be given the right-of-way in instances of 

simultaneous flights. 

3. Predetermined procedures will be in place in case of necessary flight aborting due 

to safety breaches or potential danger. This is to include unsafe weather patterns 

and conditions that would make UAS flight uncontrollable. 

4. I, Mason Geiger, will be the sole PIC and have maintained a minimum of 100 

hours flying time of unmanned aircraft systems. At least 35 of those 100 hours 

have been spent in operations of the specific DJI Inspire 1 type. 

5. All flights will decease upon reaching 30% battery life, permitting sufficient flight 

time to land safely. 

6. UAS will operate below 400 ft. and within a flight radius of 1000 ft. of PIC. 
Specific Exemption Requests 

• Due to the given size, weight, speed, and operating area, we request exemption from 14 

CFR part 21, Subpart H (Airworthiness Certificates) and 91.203(a) and (b) 

(Certifications required), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR part 11 and 

Section 333 of P.L. 112-95 (Section 333).

• Exemption from 45.23 “marking of the aircraft” is requested because the UAS has no 

cabin, cockpit, or pilot station on which to mark certain words or phrases. Further, the 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller 

than the minimal lettering requirement. 

• We request an exemption from 91.7(a), which prohibits the operation of an aircraft 

without an “airworthiness certificate.” There is currently no certificate that applies to 

our request of operations. 

• We request an exemption from: 91.405(a); 91.407(a)(1); 91.409(a)(2); and, 91.417(a) and 

(b). Maintenance inspections only apply to aircrafts with an “airworthiness certificate.” 

• Exemption from 91.9(b)(2) is requested, which requires an aircraft flight manual in the 

aircraft. There are no pilots or passengers on board the UAS.

• Exemption from 91.119 is requested, which prescribes safe altitudes for the operation of 

civil aircraft. Our UAS will not reach the altitude of 400 feet above ground level (AGL) 

and will also only operate in safe areas away from the public and traffic. 

• Exemption from 91.121 is requested. Altimeter settings is not valid since the UAS 

utilizes electronic GPS with a barometric sensor.

• Exemption from 91.151(a) is requested. Fuel requirements for flight in “VFR 

conditions.” The UAS is 100% electric, and two low battery alerts are issued per the 

operating documents. 

I respectfully request exemption under Section 333 to enable Mason Geiger Photography 

and Film, LLC to operate efficient, limited, and low-risk commercial UAS operations for 

the purposes stated, adhering always to the personal space and privacy of citizens and 

property while keeping airspace safe. 

Respectfully, 

Mason Geiger 

Mason Geiger Photography & Film, LLC