Petition for Exemption 333

Petitioner SEVENsCamp, LLC

Lynwood Douthett CEO/Senior Producer

Page 1 of 4

December 27, 2015

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 

Washington, DC 20590

Petitioner:

SEVENsCamp, LLC

Lynwood D. Douthett CEO / Senior Producer

4401 Atlantic Ave. Suite 200

Long Beach, CA 90807

Cell: 310 303-0413

Email: lseven@sevenscamp.com

Website: www.sevenscamp.com

SUBJECT: Petition for Exemption from H.R.658 - FAA Modernization and Reform Act of 2012

Section 333 and Under 14 CFR 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

1. Sections from which exemptions are sought: Application is hereby made for exemption 

from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFR Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. SEVENsCamp, LLC wishes to operate Unmanned Aircraft Systems for commercial 

purposes to include (but not limited to) closed set motion picture and television filming 

production, videography, inspections and analyses. This relief is sought because 
Petition for Exemption 333

Petitioner SEVENsCamp, LLC

Lynwood Douthett CEO/Senior Producer

Page 2 of 4

commercial use of UAS’s is currently prohibited by law unless performed under an 

exemption.

b. This exemption will cover the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources:

i. Yuneec Typhoon Q500 4k and Tornado H920 

ii. Freefly ALTA

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data obtained by use of 

manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., 

powerline inspection) and due to other dangerous activities that can be 

avoided (e.g., scaffolding/rigging failures during stack or bridge inspections)

ii. Reduces the cost of obtaining such information, which benefits consumers 

and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon 

emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and 

Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved 

by qualified personnel such as those authorized by Yuneec and or Freefly (or 

equivalent), and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by three individuals (the UAS crew) who 

will maintain verbal communication capability with each other at all times 

during the flight, and the PIC and VO will remain stationary on the ground during 

the flight operations. The third member of the crew (the videographer) may be 

mobile on foot.

i. A Pilot in Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private 

pilot license) screened by the TSA

2. A third Class medical certificate issued under 14 CFR 67.

3. A Bi-annual Flight review under 14 CFR 61.56

4. A completion of a course of instruction in safe UAS flying 

conducted by Unmanned Experts Inc. (or equivalent 

instruction).

5. At least 200 cycles and 25 hours of flight experience with 

a UAS rotorcraft. Such cycles and hours may be gained 
Petition for Exemption 333

Petitioner SEVENsCamp, LLC

Lynwood Douthett CEO/Senior Producer

Page 3 of 4

during flights under this exemption if safe distance is 

maintained from persons in accordance with 14 CFR 

91.119.

ii. A Visual Observer.

d. All flight operations will be conducted in accordance with valid Certificates of 

Authorization.

e. All Flight operations will comply with the following:

i. The manufacturers Aircraft Flight Manuals and operations guidelines

ii. SEVENsCamp flight operations policies including lost communication 

and other emergency and safety procedures.

iii. Conducted in VMC conditions during daylight hours

iv. PIC and VO will maintain VLOS at all times.

v. Pre-flight inspections (including ground control station) and safety 

risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet AGL.

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into class B, C or D airspace or published approach, SID 

or STAR, or take place within 5 miles of an airport.

ix. In the event that flight operations require flight within five miles of 

an airport; before the start of the flight operation the PIC will first 

1. Obtain prior permission and clearance from the airport 

ATC or Airport Management. 

2. Obtain a letter of agreement with that airport’s 

management or otherwise be permitted by a COA issued 

to the exemption holder. The letter of agreement with 

the airport management will be made available to the 

Administrator or any law enforcement official upon 

request. During such operation, the PIC will maintain in 

constant radio contact with the airport ATC or the Airport 

Management through to the completion of the flight 

operation.

x. Not be made near persons as required in 14 CFR 91.199 and not over 

persons on the ground without their prior permission.

xi. Each flight will be logged in both the PIC’s logbook and the aircraft 

logbook.

xii. Not to exceed 75% of the battery or fuel capacity of the aircraft or, 

30 minutes whichever comes first.

xiii. Any incidents will be reported within 24 hours of occurrence to the 

FAA.

xiv. Any accidents will be reported to both the FAA and the NTSB in 

accordance with 49 CFR 830 Subpart B 830.5, 830.6, Subpart C

830.10 and Subpart D 830.15 (a) and (c)
Petition for Exemption 333

Petitioner SEVENsCamp, LLC

Lynwood Douthett CEO/Senior Producer

Page 4 of 4

xv. SEVENsCamp will maintain liability insurance of at least $1,000,000 

issued by Transportation Risk Management, Inc. (or equivalent 

qualified insurer).

xvi. Any applicable local FSDO requirements.

xvii. All other applicable regulations concerned with the commercial 

operation of UAS aircraft.

xviii. Aircraft will use 2.4GHz for control of the aircraft, and 5.8 GHz for 

sending data.

Please advise us of any additional information or changes that are required.

Sincerely, 

Lynwood D. Douthett

CEO/ Senior Producer

SEVENsCamp, LLC