October 5, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of

2012

Name and Address of Petitioner

James Zura, owner

Zura’s Production Team, LLC

2043 Round Spring Dr.

Kingwood, TX 77339

(832) 265-4215

jim@zuraproductions.com

Introduction

As set forth herein, to commercially operate small Unmanned Aircraft Systems (UAS) safely and legally

in the National Airspace System (NAS), James Zura of Zura’s Production Team, LLC, Kingwood, Texas,

seeks an exemption from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the

FAA Modernization and Reform Act of 2012.

Section 333 states that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as

a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, and

operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a

threat to national security. The grant of such an exemption is consistent with Congress’ intent,

reflected in Section 333, that safe systems be permitted in the national airspace prior to the issuance

of final regulations governing general use of these systems.

Being “unmanned aircraft and associated elements, including communication links and the

components that control the unmanned aircraft that are required for the pilot in command to operate

safely and efficiently in the national airspace system,” Zura’s Production Team’s UAS meet the Section

331 definition of “small unmanned aircraft.”

Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace

system as it is in the public’s interest to do so. We would like to operate our small UAS(s) prior to the

time period by which the Reform Act requires the FAA to promulgate rules governing such craft,

thereby providing direct experience and valuable information for formal regulation.

Zura’s Production Team intends to use small UAS to provide aerial photography and videography

services to businesses, organizations and community members. See the Public Benefit section of this

document for more details.
• enable businesses to improve marketing and outreach through the use of 

state-of-the-art aerial photography and videography

• help to inspect buildings and structures, and map landscapes in a safe, cost-effective manner

• provide economic stimulus and public benefit by providing an effective means by which

companies or individuals can use up-to-date, high-quality photos and videos to learn

about properties, neighborhoods and communities

• help communities realize economic benefit by encouraging public participation and

encouraging tourism; by showcasing community facilities and landscapes; and by

documenting community events in low-cost ways not previously available to them

• increase awareness/knowledge of the amenities of a local area by the general public and by

visiting tourists

• provide non-profit organizations as well as schools and universities and local

municipalities ways to showcase facilities, document events, and educate the public

• aid in search and rescue operations and accident investigators.

Qualifications / Experience:

James Zura, owner of Zura’s Production Team (TPT) has the following qualifications:

• Television Network videographer for the past 25 years, with assignments for practically every 

major U.S. TV network, and many international media; in addition to hundreds of Industrial 

Video projects. TPT’s scope of work has often included doing aerial videography / photography

from traditional helicopters. (Client List attached- Exhibit A)

• Vetted and cleared by the TSA (extensive background checks) and holds a current TWIC card. 

(Exhibit B) 

• He has also regularly been cleared by the Secret Service to work one-on-one with President 

George H.W. Bush. (Photo attached with Pres. Bush when he parachuted on his 80th birthday - 

Exhibit C)

• Licensed Insurance Adjuster. During major catastrophes (hurricane, flood), Zura accepts 

assignment work - both adjusting and photography. (License – Exhibit D)

• Holds three FEMA Certificates for National Incident Command Systems (NIMS) training:

o IS-00700.a – Introduction to NIMS

o IS-00702.a – NIMS Public Information Systems

o IS-00100.b – Introduction to Incident Command System ICS-100 (Exhibits E-1,2,3)

• Has flown small UAS’s non-commercially for well over a year, and spent more than 50 hours in 

online training. An onsite checklist is performed for each flight from the Flight Operations and

Procedures Manual , consisting of 23 Pre-Flight items, 18 Takeoff, Flight, and Landing items, 

and 15 Post-Flight items. (Exhibit F)

• When planning a project at a plant site, advance preparations and precautions are taken with 

the Safety Officers to create a site- and flight-specific Job Safety Analysis (JSA) form, reviewed 

by all involved (Exhibit G)

• Zura is a part-time Instructor at the Law Enforcement Management Institute of Texas,

participating in the training of law enforcement officers in their interactions with the media.

• Regularly produce industrial training videos for the petrochemical industry, where frequently 

requested to use small UAS for video inspection services (once granted Section 333 exemption).
We understand that we are entitled to submit a Petition for Exemption if we believe that following a

rule will burden us, we can provide a level of safety at least equal to that provided by the rule, and

our request is in the public interest. Therefore we seek relief from the following sections of the

current regulations:

14 CFR 21 subpart H - Certification procedures; Airworthiness Certificates

14 CFR 45.23 - Display of Marks

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

14 CFR 91.105 Flight crewmembers at stations

14 CFR 91.109 (a) Flight instruction

14 CFR 91.119 (c) Minimum safe altitudes

14 CFR 91.121 - Altimeter settings

14 CFR 91.151 (a) - Fuel Requirements for Flight in VFR Conditions

14 CFR 91.203 Carrying Civil Aircraft Certification and

Registration

14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required;

Operation after maintenance, preventive maintenance, rebuilding or alteration

14 CFR 91.417 (a) & (b) Maintenance Records

14 CFR 91.7 (a) - Civil Aircraft Airworthiness

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.

This application is similar to many which have received FAA approval. As stated in Exemption

#11639, the FAA has found that the enhanced safety achieved using an UAS with the specifications

described by herein, and carrying no passengers or crew, rather than a manned aircraft of

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good

cause to find that such exemption is in the public interest. Since we are applying at a time when

the FAA is using a “summary grant process” be informed that while developing this request we

reviewed, among others, exemptions #11636, #11639, #11595, #11596, #11564, #11569, and

#11616.

Extent of Relief and Reason for Seeking Relief; Why the Exemption would not

Adversely Affect Safety, or How the Exemption would Provide a Level of Safety

Equal to Existing Rule

Part 21 Airworthiness Certification; Subpart H Certification procedures for products and parts,

Airworthiness Certificates

This section outlines requirements for the issue of design and production approvals, airworthiness

certificates, and other airworthiness approvals. We seek relief from this rule because the size,

weight and enclosed operational area of our UAS, as described elsewhere in this document, permit

exemption from Part 21 because our UAS meet and exceed an equivalent level of safety pursuant

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform

Act. Therefore, relief from 14 CFR part 21, and any associated noise certification and testing

requirements of part 36, is not necessary.
Instead of following this requirement, we will as outlined in this document, as per our Flight

Operations and Procedures Manual and Training Manual, (Exhibit F) Zura’s Production Team seeks

to uphold the same level or exceeded level of safety as described in Part 21 of 14 C.F.R. Therefore

this exemption will not adversely affect safety or will provide a level of safety equal to the existing

rule.

14 CFR 45.23 Display of Marks

This section outlines regulations requiring specific location(s) and size of aircraft marks. We seek

relief from this rule because, given the size of our UAS, and the lack of cabin, cockpit or pilot station,

two-inch lettering is difficult to place on such small aircraft.

Instead of following this requirement, we will mark the UAS in lettering that is as large as

practicable by placing an N number registered with the FAA on its fuselage so that the PIC, VO, or

other observers will see the markings. This exemption will therefore not adversely affect safety or

will provide a level of safety equal to the existing rule.

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

This section describes regulations concerning certification of pilots. We seek relief from this rule

because the risks associated with the operation of a UAS are lesser than and often uncorrelated

with the risks associated with the commercial and private aircraft operations contemplated by Part

61 when drafted. The skills required to fly large, manned aircraft are substantially different from the

skills required to remotely operate a small UAS. Also, manned aerial vehicles weighing significantly

more than small drones (such as ultralight vehicles) as well as small UAS legally operated by

hobbyists, operate without the need for pilot certification.

Requiring a private or commercial pilot certificate would provide no appreciable safety benefit and

would needlessly impose an undue burden of time and cost on Zura’s Production Team, most

particularly in light of the FAA’s Small UAS Notice of Proposed Rulemaking which proposes that

small UAS pilots be considered ‘operators’ required to meet certain requirements that do not

include pilot’s license.

Instead of following this requirement, to minimize risk and maximize safety, all UAS operations will

be controlled and limited, and all flights will be planned and coordinated prior to operations:

• prior to operations, Zura’s Production Team’s PIC(s) will go through a documented process of

dedicated ground school and flight lessons in accordance with manufacturer and industry

guides.

• all PIC’s will only operate the UAS as stated in this document and in our Flight Operations and

Procedures Manual, flying at altitudes well below the permissible limits for other civil aircraft,

and within a geographical envelope under the control of Zura’s Production Team clients.

• the PIC will be designated before a flight and will not transfer control at any time during a flight.

• Zura’s Production Team PICs will comply with upcoming FAA Operator Certification

and Responsibilities once they are finalized.

This exemption will therefore not adversely affect safety or will provide a level of safety equal to the

existing rule. More information about pilot safety can be found in the Operation of the Unmanned

Aircraft to Minimize Risk to the NAS, People and Property section of this document.
14 CFR 91.105 Flight crewmembers at stations

This section outlines regulations for flight crewmembers inside an aircraft. We seek relief from this

rule because there is no flight crew onboard a small UAS.

Instead of following this requirement, in keeping with the direction of the regulation, the PIC of the

UAS and VO will be at their respective crewmember stations on the ground during takeoff and

landing as well as the complete duration of the flight. By instituting this procedure this exemption

will therefore not adversely affect safety or will provide a level of safety equal to the existing rule.

14 CFR 91.109 (a) Flight Instruction

This section provides that 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. We seek

relief from this rule because UAS do not have fully functioning dual controls.

Instead, flight control is accomplished through the use of a control box that communicates with the

aircraft via radio communications. The FAA has approved exemptions for flight training without fully

functional dual controls for a number of aircraft and for flight instruction in experimental aircraft.

This exemption will therefore not adversely affect safety or will provide a level of safety equal to the

existing rule.

14 CFR 91.119 (c) Minimum safe altitudes: General.

This section establishes minimum altitudes for operation of civil aircraft. We seek relief from this

rule because the services we intend to provide for the public good may require photo or video

images captured from an altitude of less than 500 feet.

Instead of following this requirement, all UAS flights will be conducted with within visual line of

sight and with prior permission from the owner of the property or municipality. All persons,

vessels, vehicles, not directly involved with the operation will be notified and cleared of the area

where UAS operations will be conducted. Given our policies of advance notice and access

restricted area, and given the size, weight, maneuverability and speed of our UAS, we will maintain

an equivalent or higher level of safety of that described in this rule.

14 CFR 91.121 Altimeter settings

This section defines regulations for altimeter settings. We seek relief from this rule concerning

altimeter settings because: our UAS has no altimeter settings. Instead, electronic GPS downlinks

telemetry data in real time to the PIC’s ground-based on-screen display as to the altitude (AGL) of

the UAS above the takeoff location.

This exemption will not adversely affect safety, as our PIC will provide a level of safety equal to the

existing rule by confirming the altitude of the launch site shown on the GPS altitude indicator prior

to each flight.

14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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.” We seek relief

from this rule because our UAS runs on battery instead of fuel, most of our UAS flights last less than
the 30 minute reserve requirement, and we do not fly at night.

Instead of following this requirement, an equivalent level of safety will be achieved by following the

UAS manufacturer’s operating documents with regard to battery voltage. To ensure safety and

maintain adequate communication between radio control and the UAS, our PIC will not begin a

flight with a battery holding less than 75% charge; and will not begin a flight unless (considering

wind and forecast weather conditions) there is enough power to fly to the intended landing point at

normal cruising speed and land the UAS with no less than 30% of battery power. A landing

sequence will be initiated at the 30% warning and the UAS automatically initiates landing sequence

at 15% charge while still under PIC control.

Through implementation of these procedures, this exemption will not adversely affect safety or will

provide a level of safety equal to the existing rule.

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certification within an aircraft. We seek relief

from this rule because our small UAS weighs less than 10 pounds, and is operated without an

onboard pilot. There are no passengers or crew; and no cabin or cockpit entrance upon which to

display certificates.

An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the PIC will have immediate access to them, and be able to provide them upon request.

14 CFR 91.405 (a) Maintenance required; 14 CFR 91.407 (a) (1) Operation after maintenance,

preventive maintenance, rebuilding, or alteration; 14 CFR 91.409 (a) (2) Inspections; and

14 CFR 91.417 (a) & (b) Maintenance records

We seek relief from these 4 rules because these regulations only apply to aircraft with an

airworthiness certificate, and will not, therefore, apply to Zura’s Production Team’s UAS. We seek

relief also because the FAA has not developed maintenance standards for UAS that would allow an

UAS operator to meet the part 91 maintenance requirements. In particular, there are no individuals

authorized by the FAA to approve a UAS for return to service or to conduct the initial airworthiness

and annual return to service inspections as required.

Instead of following these requirements, we will:

• perform preventative and required maintenance on each aircraft as per the owner’s manuals.

• inspect our UAS before and after each flight as per our Flight Operations and Procedures

Manual to ensure that the UAS is in a condition for safe flight.

• will conduct a test flight on each aircraft following any major repairs.

• will properly note all discrepancies, maintenance, and alterations in a Maintenance Log.

Therefore this exemption would not adversely affect safety or would provide a level of safety equal

to the existing rule. More information about maintenance procedures can be found in the Operation

of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this

document.

14 CFR 91.7 (a) Civil aircraft airworthiness

This section states that “no person may operate a civil aircraft unless it is in an airworthy condition.”

We seek relief from this rule based on the fact that Zura’s Production Team’s UAS will not require an
airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an

airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary.

An equivalent level of safety will be achieved through the guidance from our Flight Operations and

Procedures Manual, pilot training, and operational risk management for each activity.

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements

This section requires an aircraft flight manual in the aircraft. We seek relief from this rule based on

the small size of our UAS and the fact that our UAS carries no onboard pilots or passengers. Given

its size and configuration there is no room or capacity in our UAS to carry such an item. This

regulation is therefore inapplicable.

An equivalent level of compliance will be achieved by keeping our versions of these documents at

the ground control point where the PIC will have immediate access to them, and be able to provide

them upon request.

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Public Benefit: how our request would benefit the public as a whole

Serving the Public Interest: In addition to creating a body of work that positively perpetuates the 

responsible use of small UAS photography, qualifications, experience, and requests for aerial photo 

work do serve the Public Interest:

• In the event of a major catastrophic incident, my credentials with the TWIC card and Insurance 

Adjuster card will allow me immediate access to the front lines of an incident without delay, 

giving me the ability to gather and disseminate valuable aerial images to law enforcement, 

community, insurance companies, and the media as needed. As has been well noted, the use of 

small UAS’s has proven invaluable in quickly providing visual assessments in areas that cannot 

be accessed safely by personnel.

• The NIMS model provides a national system of Emergency Response that includes an assigned 

Videographer. Having the ability to use my small UAS will greatly enhance my ability to serve 

this role, providing First Responders with birds-eye views of an incident.

• With 25 years’ experience as a producer of training videos for chemical plants, my ability to do 

aerial inspection services on process columns, tanks, flare stacks, etc., will provide a valuable 

method in enhancing the safety of the plants. The small UAS is capable of getting shots that 

cannot be achieved by other aerial methods, and is phenomenally safer than close hovering of a 

traditional helicopter.

• As the Producer of the official tourism videos for the State of Arizona, State of Florida, Island of 

Barbados, and Island of Curacao, adding the unique perspective that can only be achieved by a 

small UAS can provide communities with a special presentation benefit.

Granting Zura’s Production Team the ability to operate small UAS safely and legally in the National

Airspace System will have the following positive economic and societal impacts on local

communities, businesses, organizations and community members:
• benefit local business marketing by offering state-of-the-art aerial photography and

videography

• help to inspect buildings and structures, and map landscapes in a safe, cost-effective manner

• provide economic stimulus and public benefit by providing an effective means by which

companies or individuals looking to relocate to an area can use up-to-date, high-quality

photos and videos of real estate properties to learn about properties, neighborhoods

and communities

• help communities realize economic benefit by encouraging public participation and

encouraging tourism by showcasing community buildings and landscapes and by

documenting community events in low-cost ways not previously available to them

• increase awareness/knowledge of the amenities of a local area by the general public and by

visiting tourists

• provide non-profit organizations as well as schools and universities and local

municipalities ways to showcase facilities, document events, and educate the public

• aid in search and rescue operations and accident investigators.

All of the above services:

• are otherwise unavailable to the public, given the UAS’s the ability to:

o safely capture images from 0 to 400 feet.

o create images that are more up-to-date and more closely defined than Google

Earth-type satellite images.

o create images at prices lower than that of traditional helicopter and airplane

o photography and videography.

• increase safety of and reduce risk to the public and the NAS by:

o replacing large manned helicopter and airplane flights with small UAS flights, thereby

reducing air and noise pollution as well as the dangers inherent in flying aircraft loaded

with crewmembers and combustible fuel close to people and property.

o offering safer ways to inspect tall structures and remote locations, e.g. removing the

o physical risk of climbing on a roof or structure to inspect it.

• reduce environmental pollution and reliance on fossil fuels by replacing fueled aircraft

flights with battery-operated UAS flights.

Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and

Property

Concerning our commercial UAS flight operations, we take seriously our obligation to clearly

define operational borders, and implement operational risk management procedures to ensure

the public safety of persons and property both in the air and on the ground.

While Zura’s Production Team is based in Houston, Texas, we often contract with clients

throughout the U.S. Our area of intended operations include a range of population areas, from

urban to rural, with some areas, especially coastal ones, experiencing seasonal increases and
decreases in activity from both people and aircraft. Our operations will take into account these

variations in populations and activities. My experience in tourism videos, industrial plant operations, 

including the planning and implementation of drills and safety videos enables me to apply

operational risk management techniques when assessing situations where the safety of the general

population and the NAS are concerned.

Meeting or exceeding COA requirements to perform commercial operations in low-risk, controlled

environments, our UAS will be operated:

• during daytime Visual Flight Rules (VFR) conditions and visual meteorological conditions

(VMC).

• within visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual Observer (VO),

in accordance with the statutory Section 333(b)(1) mandate.

• in such a manner that the PIC and VO are able to communicate verbally at all times; and

that the VO can assist the PIC with seeing and avoiding other air traffic and other groundbased obstacles/obstructions.

We will not operate our UAS:

• at altitudes exceeding 400 feet AGL

• in winds exceeding 25 knots.

• from any moving vehicle or device.

• at airspeeds greater than the maximum recommended by the manufacturer.

• less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility

is less than 3 statute miles from the PIC.

• unless (considering wind and forecast weather conditions) there is enough available power

for the UAS to conduct the intended operation and to operate after that for at least 5

minutes or with the reserve power recommended by the manufacturer if greater.

• near areas where general public is within 200 feet; or directly over any person except

authorized Zura’s Production Team personnel and consenting inspection personnel, unless

operations nearer to the PIC do not present an undue hazard to those persons; or unless

the owner/controller of any vessels, vehicles or structures has granted permission for

operating closer to those objects and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present an undue hazard.

• near power lines, wind turbines, or elevated lights; or within areas of airspace restrictions such

as the one imposed by the National Park Service.

• near airports, heliports, or military bases; more specifically:

o In accordance with the statutory Section 333 mandate regarding proximity to

airports, we will stay certain distances away from airports or heliports: 5 NM from an

airport having an operational control tower; or 3 NM from airport w/ a published

instrument flight procedure, but not operational tower; or 2 NM from an airport

w/out published instrument flight procedure or an operational tower; or 2 NM from

a heliport with a published instrument flight procedure.

o We will not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise 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.

● If we intend to conduct operations in controlled airspaces which have existing

requirements to notify Flight Standards District Offices (FSDOs) prior to operations – such

as motion picture and television filming, or pipeline and powerline patrol – we will contact

the local FSDO and comply with their procedures, such as filing a NOTAM as per their

request.

Our Flight Operations and Procedures Manual, will include procedures for:

• conducting a preflight safety risk assessment to determine that the UAS is in a condition for

safe flight, i.e. completing a preflight inspection checklist to ensure the UAS’s airworthiness.

If the inspection reveals a condition that affects the safe operation of the UAS and/or the

Ground Control Station, the aircraft will be prohibited from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight.

• maintaining a Flight Log (noting UAS flight time, Control Unit operation time, incident

reports, etc.); and making said Log available to the FAA if requested.

• conducting initial and ongoing training of PICs and VOs, to include classroom training,

and training, proficiency and experience-building flights; all persons not essential for

flight operations will be considered nonparticipants, and the PIC will operate the UAS

with appropriate distance from nonparticipants in accordance with 14 CFR 91.119.

• evaluating the operational abilities of PICs and VOs on a regular basis.

• maintaining and repairing the aircraft to ensure that it is in a condition for safe operation by:

o following the UAS manufacturer’s maintenance, overhaul, replacement inspection,

and life limit requirements and safety bulletins for the aircraft and its components.

o installing firmware updates provided by the manufacturer.

o keeping a Maintenance Log noting all maintenance, inspection, alterations, and

status of replacement/overhaul component parts in the aircraft records, including

total time in service, description of work, and signature of the authorized person

returning the UAS to service; and making said Log available to the FAA if requested.

o verifying condition of flight batteries and calibrating the Inertial Measurement

Unit (IMU) using manufacturer software.

o conducting a functional test flight on any UAS that has undergone maintenance or

alterations that affect the UAS operation; said functional test flight will be

conducted by a PIC with a VO and so as to not pose an undue hazard to persons

and property; and recorded in the aircraft records.

• procedures that ensure that the planned operation can be completed safely, such as:

o checking local sectional (air) charts, notam (notice to airmen), etc. prior to the flight.

o conducting a pre-flight visual survey of the area to consider characteristics of the

area of intended operation(s) and the associated potential hazards regarding

proximity to populated areas.

o remaining clear and giving way to all manned aviation operations and activities at

all times.

o aborting a flight and landing the UAS at the nearest and safest ground point in

the event of safety breaches, potential danger, unpredicted obstacles or

emergencies.

o using a fresh, fully-charged battery with each flight as a safety precaution, to ensure

safety and maintain adequate communication between radio control and the UAS;

and not operating our UAS at or below manufacturer recommend minimum charge
levels for operation.

Also:

• Flight operations will be performed only at the request of and with the authorization

and permission of clients (property owner/controller) or their authorized

representatives.

• Caution signs will be placed at the site of aerial operations to warn people that

aircraft operations are in progress.

• Our Client Agreements will reserve us the right to decline a photo shoot if conditions of

the location (e.g. proximity of power lines) may cause unacceptable risk; and to

reschedule a photo shoot if weather conditions such as precipitation or wind speed

become a factor.

• The operating documents for our UAS, and any revisions, will be accessible during UAS

operations and made available to the Administrator or law enforcement official upon

request.

• We carry comprehensive general liability insurance coverage and an additional

insurance policy specifically covering our UAS.

Summary for Federal Register

James Zura of Zura’s Production Team LLC, Kingwood, Texas, seeks exemption from Federal Aviation

Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of

2012 for the purpose of commercially operating small Unmanned Aircraft Systems (UAS) safely and

legally in the National Airspace System.

Specifically, Zura’s Production Team seeks relief from the following sections of the current

regulations: 14 CFR 21 subpart H - Certification procedures; Airworthiness Certificates; 14 CFR 45.23

- Display of Marks; 14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations; 14 CFR 91.105

Flight crewmembers at stations; 14 CFR 91.109 (a) Flight instruction; 14 CFR 91.119 (c) Minimum

safe altitudes; 14 CFR 91.121 - Altimeter settings; 14 CFR 91.151 (a) - Fuel Requirements for Flight

in VFR Conditions; 14 CFR 91.203 Carrying Civil Aircraft Certification and Registration; 14 CFR 91.405

(a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required; Operation after maintenance,

preventive maintenance, rebuilding or alteration; 14 CFR 91.417 (a)&(b) Maintenance Records;

14 CFR 91.7 (a) - Civil Aircraft Airworthiness; 14 CFR 91.9 (b) Civil aircraft flight manual, marking,

and placard requirements.

The enhanced safety achieved using an UAS with the specifications described herein, and carrying

no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying

crew in addition to flammable fuel, should give the FAA good cause to find that such exemption is in

the public interest. By granting this request for exemption, the FAA will facilitate the smooth

integration of UAS into the NAS.
Additional Information

Design Characteristics, Aircraft Performance and Performance Limitations, and

Conditions of sUAS to be Operated

DJI Inspire 1:

• utilize 4 counter-rotating propellers for balance, control and stability

• are equipped with GPS to maintain geospatial orientation and position

• use Return Home safety technology and Auto Landing feature if UAS loses transmitter signal

• are controlled primarily through FCC approved RF spectrum transmitter/controller/receivers;

• and FCC approved RF spectrum EIRP with transmitting power of 100 mW for dedicated wifi

transmitter/receiver between sUAS, Range Extender attached to transmitter and mobile

viewing device displaying operational telemetry and video/photography functions.

• send real time video and telemetry information is transmitted back to a ground control

station, allowing PIC to monitor battery level, GPS signal strength, altitude (AGL),

distance from PIC, camera imagery, and control camera angle.

• have failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by

the onboard flight controller and maximum altitude can be preprogrammed by the PIC.

• have audible and visual sequential low battery warnings set at 30% charge and 15% charge

remaining. The sUAS automatically initiates landing sequence at 15% charge while still

under PIC control. The onboard flight controller will warn the pilot via telemetry and

external lighting cues before reaching a low battery state. An automatic termination of

flight and landing will be initiated when the battery reaches a predetermined low state

• Gross weight of less than 7 pounds including camera and battery

• Cruising speed of 15 knots with maximum speed of 42 knots and maximum altitude of 4500m

• Maximum flight time of 18 minutes

• FCC compliant Radio Frequency (RF) spectrum 5.725~5.825 GHz and 2.400~2.483 GHz

• manual available at http://www.dji.com/product/inspire-1/download

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Zura’s Texas Production Team, LLC

Partial Client List

www.zuraproductions.com 713-446-6458

NETWORK TELEVISION

ABC

America’s Most Wanted

Animal Planet

Associated Press Television

CBS 

CNBC

CNN

Court-TV

C-SPAN

Danish Television Network

Discovery

E! Network

ESPN

Fox Sports

Fox News Channel

Fuji Television (Japan)

The History Channel

The Learning Channel

Madison Square Garden 

Network

MSNBC

National Geographic Film & TV

National Mobile Television

NHK (Japanese Television)

Oprah Winfrey Show

O’Reilly Factor

PGA Tours

RAI – Italian TV Network

Reuters

Rivera Live

Telemundo

Televisa

CORPORATE / INDUSTRIAL

American Greetings

Anadarko

Anheuser-Busch

Arizona Office of Tourism

Barbados Tourism Authority

Barnes & Noble

BASF

Bechtel Engineering

Brown & Root

Cambridge Energy Research

Caterpillar 

Celanese

Challenger Center (NASA)

Chase Bank

Coca-Cola Foods

Compaq Computers

Conoco

Continental Airlines

Curacao Tourism Board

Deer Park LEPC

Discovery/ Animal Planet

ExxonMobil

FLA USA (Florida Tourism) 

Fluor Daniel

FMC

Food Marketing Institute

Halliburton

Hewlett Packard

Hines Interests

The History Channel

International Association of 

Geophysical Contractors

Jacobs Engineering

Kaneka Texas

Kinkaid School

Living Centers of America

M.W. Kellogg Company

Microlene U.K., Ltd

Microsoft

Nat'l Assoc of Home Builders

Nike

Offices of George Bush

The Oil Museum

Pepsi Cola

Pennzoil

PGA Tours

Port of Houston Authority

Price Waterhouse

Promis Systems/Motorola

Purina

Republican National 

Convention

Ronald McDonald House

Rohm & Haas

Salvation Army

Schult Homes

Seneca Resources

Service Corporation 

International

Shell Oil Co

Solvay Polymers

Sony PlayStation 

Southwest Airlines

Space Industries

St. Joseph Hospital

St. Martin’s Episcopal Church

Livingston Taylor

Texas Education 

Agency/Region IV

Texaco

Torch Energy Advisors

Valero

Westinghouse 
Exhibit B, 

TWIC Card

Exhibit C:

James Zura with Pres. George H.W. Bush

Exhibit C: Insurance Adjuster's License
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Air Zura Inspire

FLILGHT CHECKLIST - DJI INSPIRE 1 QUADCOPTER

• PRE-FLIGHT: QUADCOPTER & CONTROLS (copter directions in blue)

1. Place Quadcopter on Takeoff / Landing Zone Pad (smooth surface)

2. Insert Battery into Quadcopter – leave off

3. Power up Samsung Phone and Samsung Tablet and put in “Airplane Mode” to defeat

incoming signals; turn Bluetooth off, exit any open apps

4. Mount Android Phone & Tablet onto Master and Camera remote controllers, plug in USB’s

5. Mount HDMI Monitor on stand, mount DVX battery or other power supply, connect to

Camera Remote with HDMI – mini HDMI cable

6. Be sure flight mode switches are in “P” (Positioning, as in Global Positioning) on Remote

Controllers

7. Set antennas straight up & parallel (flat side to copter) (use 45° detent if holding the

Controller at an angle)

8. Power up Main Remote (same button routine as above)

9. Power up battery on Quadcopter, press button once short then long

10.Click RTH lever on Main Remote back and forth 4 times (Quadcopter landing gear raises)

11.Power off Quadcopter by pressing button on battery once short, then long. Confirm power

off.

12.Check / clean camera lens

13.Remove gimbal caps

14.Be sure there is an SD card in the camera with ample free space

15.Attach Camera / Gimbal

16.Power Quadcopter on (as in #1 above); observe as craft and gimbal go through initialize

routine

Page 1 jim@zuraproductions.com cell: 832-265-4215 www.zuraproductions.com

©2015 James A. Zura all rights reserved

EXHIBIT F, Page 1 of 3
17.Launch DJI GO app on each device, confirm camera feed on both Android units and HDMI

Monitor

18.Select Calibrate Compass from menu

19.Perform physical Calibration Routine. Confirm success

20.Place Quadcopter on Takeoff / Landing Zone Pad – do not move

21.Install propellers

22.Check all Quadcopter settings on DJI GO app

23.Check all Camera settings on DJI GO app

• TAKEOFF & FLIGHT:

o Operate in GPS Mode

o Power up rotors

o Observe Status Screen- should say “Safe to Fly”, with number of locked-in satellites

listed (> 10)

o Check for any other warnings on the screen

o Throttle up and hover at 5-6 feet (landing gear retracts)

o Camera Operator or Assistant does 360-degree walkaround

o Observe all parts, confirm stability

o Begin flight

o Start / Stop recording as needed

o CAMERA AND COPTER DIRECTIVES – We use standard Camera Directives instead of

aviation terminology:

 ROTATE left / right: the Quadcopter rotates on its axis (YAW)

 CRAB left / right: the Quadcopter travels left / right (ROLL)

 FORWARD / BACK: Quadcopter direction of travel (PITCH)

 PED (pedestal) up / down: Quadcopter raises up / down (THROTTLE)

 PAN right / left: Camera Gimbal pans left / right on Gimbel

 TILT up / down: Camera Gimbal tilts up / down

o Maintain adequate buffer zones between aircraft and personnel

o Follow Flight Plan, announcing turns, changes in elevation

o In case of unusual operation / loss of orientation, throttle the copter straight up (this

should be no problem if the rule of not flying under anything is practiced.)

Page 2 jim@zuraproductions.com cell: 832-265-4215 www.zuraproductions.com

©2015 James A. Zura all rights reserved

EXHIBIT F, Page 2 of 3
o Monitor Battery Levels- return to base when “low battery” warning appears

o When ready to land, announce out loud “Preparing to Land”.

o Carefully land the aircraft at TLZ, or on other suitable surface (including grass) if

necessary

o If video recording was in progress, stop recording

o If there is a subsequent flight:

1. Power Quadcopter Off- pressing button on battery once short, once long:

confirm that Quadcopter has powered off (takes a few seconds- observe till unit

is silent)

2. Leave all Remote systems / components running

3. Change battery on Quadcopter, power up Quadcopter, observe initialization

4. Return to flight / recording

• POST-FLIGHT

1. Be sure Quadcopter is on TLZ or other smooth surface (and Power remains on)

2. Toggle Transformation Switch 4-5 times – observe landing gear moving into Travel Mode

3. Power down Quadcopter (once short, once long)

4. Remove battery

5. Remove Camera Gimbal, put on caps

6. Remove Micro SD Card, insert in adapter, stow in safe place

7. Store Camera Gimbal in case

8. Remove Propellers, store in case

9. Post-flight inspection of Quadcoper

10.Store Quadcopter batteries in case

11.Store Quadcopter in case

12.Power down both Remote Control Units and HDMI monitor, store

13.Remove USB & HDMI cables, store

14.Store hoods

15.Store any other accessories

Page 3 jim@zuraproductions.com cell: 832-265-4215 www.zuraproductions.com

©2015 James A. Zura all rights reserved

EXHIBIT F, Page 3 of 3
JOB SAFETY ANALYSIS JOB TITLE (and number if applicable):

Capture sUAS (Quadcopter) Video Footage of facility

DATE:

9/18-20/15

NEW

REVISED

TITLE OF PERSON DOING 

JOB: Quadcopter Pilot (PIC)

SUPERVISOR:

Tobin Kueper

ANALYSIS BY: T. Kueper

COMPANY PLANT/LOCATION: DEPARTMENT/UNIT REVIEWED BY: L. Crear,

Cyanco Winnemucca, Nevada NaCN G. Mitch, M. Jones, G. Griffin, J. 

Zura

REQUIRED PERSONAL 

PROTECTIVE EQUIPMENT:

Hard Hat, Safety glasses, Steel toed boots, Radio APPROVED BY: See above.

BASIC JOB STEPS POTENTIAL HAZARDS RECOMMENDED ACTION OR PROCEDURE

1. Move in materials and

equipment on site; permit

and set up work area.

Environmental hazards; traffic, 

work in area 

Operations personnel to identify hazards in the area and 

choose a safe place to set up. Operations personnel to 

remain with PIC throughout the procedure from setup to 

demobilization.

2. Walk through flight plan

with Operations and assess

any hazards within the flight

area

OH Electrical wires; stack 

exhaust; Cooling Tower and 

Thermal Oxidizer “exhaust”; 

process structure, piping, etc.; 

wind speed and direction

Walk around proposed flight path and identify any 

potential hazards; Check wind speed with Main gate 

(wind speed should be below 10 mph – per Quadcopter 

safety practice); keep flight path clear of stack exhaust 

and other potential sources of turbulence.

3. Identify safe take-off and

landing areas and establish

emergency landing area

Ensure no obstructions between take-off/landing area and 

all points of the flight path

4. Remove personnel from

area, issue necessary

permits and barricade area

under flight path.

Line of fire/fall risk to people 

working/walking within 250’ of 

area

Temporarily stop all Personnel working in the unit and 

barricade-tape as required pre-identified area that was set 

during walkthrough. Notify all personnel to stay clear of 

the area. Send plant-wide announcement (by PA system 

and radios) to inform personnel

EXHIBIT G - Sample Job Safety Analysis 

Page 3 of 3
BASIC JOB STEPS POTENTIAL HAZARDS RECOMMENDED ACTION OR PROCEDURE

5. Pre-flight set-up/assembly

of Quadcopter and related

inspection of equipment

Incorrect assembly, pinch points, 

strains

Follow pre-flight procedure. Use proper body 

positioning. Ensure equipment is de-energized during 

assembly/checkout

6. Conduct pre-flight checks Malfunctioning equipment Follow checklist and keep personnel clear of the area 

during pre-fight checks.

7. Clear flight areas of any

spectators in established

safe zone

8. Start Quadcopter, make

flight and take video

Equipment malfunction or loss of 

power resulting in drone falling 

or losing control 

Follow only pre-defined flight path. Barricades to keep 

personnel clear of area below flight path. Quadcopter will 

not be flown where it cannot be taken straight down 

immediately if needed.

Loss of communication; radio 

interference with communications

Confirm known radio frequencies in the unit will not 

interfere with drone control frequencies. Quadcopter 

returns to “home” location upon lost communication. 

Confirm no obstructions between drone and “home” at 

any point of flight path. Do not fly under or around any 

obstacles.

Wind or turbulence forces drone 

outside of designated flight path 

Keep drone away from sides of building, stack exhaust, 

CT exhaust, etc. Do not fly if wind speed is >10 mph. 

Reference plant Weather Station 

9. Land Quadcopter in

designated landing zone

Equipment malfunction; loss of 

power; loss of communication; 

people in intended landing area

Follow all precautions above to keep people clear of the 

area. Clearly announce intent to land. 

Page 2 of 3
10. Assess video and determine 

if more footage is needed. 

Repeat steps above if 

necessary

11. Cool down Quadcopter and 

dismantle

Pinch points, strains. Proper body positioning

12. Turn in permit and leave 

unit