Angus Media

3201 Fredrick Ave.

St. Joseph, MO 64507

www.angus.media

March 10, 2016

To Whom It May Concern:

Please see the below exemption request pursuant to Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations.

(B) Specific Sections of 14 CFR

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from:

14 CFR 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)

14 CFR 91.417(a) and (b)

(C) Extent of Relief I Seek

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

“Reform Act”) and 14 CFR Part 11, Angus Media, operator of Unmanned Aircraft 

Systems (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of designated UAS, provided such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

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Commercial operation of an UAS DJI Phantom 3 Professional, as described herein, 

which is equipped with a camera, would provide professional services in the following 

areas:

1. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and news-gathering.

2. Training to persons individually or belonging to both private and/or public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS. 

As described fully below, the requested exemption would permit the operation of 

designated UAS as set forth in this document under controlled conditions in the 

NAS that would be a) limited b) controlled c) predetermined and d) safe. Approval 

of this exemption would increase public awareness of UAS operations and enhance 

safety to aid in fulfilling 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.” 

(D) Reasons Why Granting My Request Would Be in the Public Interest

Aerial photography and has been around for a long time through manned fixed wing 

aircraft and helicopters. For small budget productions, the expense of such aerial 

photography and videography is cost prohibitive. Only larger companies can afford to

absorb such expense. Manned aircraft pose a threat to the public through the potential of 

a catastrophic crash. My sUAS poses no such threat since size and lack of combustible 

fuel alleviates any potential threat to the public. 

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

commercially flown sUASs into the national airspace system, hence the passing of the 

Reform Act. Granting my exemption request furthers the public interest through 

academic/visual awareness of the agriculture photography and videography fields. My 

ultra-lightweights UAS is battery powered and creates no emissions that can harm the 

environment. The consequence of my ultra-lightweights UAS crashing is far less than a 

full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and 

can cause catastrophic devastation to the public. The public’s interest is furthered by 

minimizing ecological and crash threat by permitting aerial photography and 

videography captured through my battery operated ultra-lightweights UAS's.

Permitting me to immediately fly within national air space furthers economic growth. 

Granting my exemption request substantially furthers the economic impact for 

companies looking to use aerial photography and videography, both of which serve as a 

stimulus to the community. 

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Additionally, our media production features consumers and food producers, and the 

use of our UAS to capture aerials will significantly aid in helping consumers understand 

how their food is raised and gain respect for those responsible for food production. 

Flights will take place with full knowledge and cooperation of property owners/managers 

and those featured within the media production.

(E) Reasons Why Granting the Exemption Would Not Adversely Affect Safety

Given the small size of the UAS involved and the restricted controlled environment 

within which it will operate, the applicant fits within that zone of safety (an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due to the size of the 

UASs and the controlled areas in which the relevant UASs will operate, approval of the 

application presents no national security issue. Given the following, the grant of the 

requested exemptions is clearly in the public interest.

Angus Media proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for an exceptional level of safety to operations. These limitations and 

conditions to which Angus Media agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes.

4. Flights will be terminated at 30% battery power reserve.

5. Flights will be operated at an altitude of no more than 200 feet AGL

6. UAS operator will be trained and certified in the proper safety and operations of 

the UAS.

7. The UAS will only operate within a controlled area as defined in the Procedures.

8. The operator will post advisor notice around the controlled area.

9. The operator will have been trained in operation of UAS generally and received 

up-to-date information on the particular UAS to be operated as required.

10. If the UAS loses communications or loses its GPS signal, the UAS will have

capability to return to a pre-determined location within the Security Perimeter and 

land.

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

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(F) A Summary To Publish in the Federal Register

(1) The Rules From Which I Seek Exemption:

14 CFR 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)

14 CFR 91.417(a) and (b)

(2) A Brief Description of the Relief I Seek:

Approval of exemptions allowing commercial operations of sUASs in the media 

industry will enhance safety by reducing risk associated with conventional aircraft 

operations and other means of elevated remote sensing involving persons. The public 

benefit served by approval of this petition is increased awareness of characteristics of 

difficult imaging targets. An sUAS weighing fewer than 11 kg and powered by sealed 

batteries eliminates virtually all associated risk inherent in operating conventional aircraft 

in close proximity to buildings or persons or otherwise elevating persons to a position 

they would be able to collect needed data. The operation of small UASs, weighing less 

than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent 

level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial 

operations.

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption and is prepared to modify or amend any part of this request to satisfy the need 

for an equivalent level of safety. I look forward to working with your office. Please contact 

me at any time if additional information or clarifications is needed.

Sincerely,

Josh Comninellis

Video Editor

Angus Media

816.383.5100

jcomninellis@angus.media 4