Video Star Entertainment, LLC 

16 Appleway Drive #6 

Kalispell, MT 59901 

info@videostarentertainment.com 

Cell Phone: 406-212-8846 

Date: 01-10-2016 

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 

11, Video Star Entertainment, LLC, owner and operator of Small Unmanned Aircraft Systems (UASs), 

request to be exempted from the Federal Aviation Regulations {FAR) listed below so that Video Star 

Entertainment, LLC may operate UASs commercially in airspace regulated by the FAA, as long as such 

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

the FAA as required by Section 333. 

Video Star Entertainment, LLC is co-owned by Jordan M Lister and Jessica L Lister. Video Star 

Entertainment, LLC will secure a PIC as operator with appropriate licensure as stipulated by the Section 

333 exemption requirements. All operations performed will be performed with public’s safety and right 

to privacy safe-guarded at all times. 

As described below, the requested exception would permit the operation of light weight (less than 55 

lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private pilot 

thereby enhancing safety and fulfilling the Secretary of Transportation's ( the FAA Administrator's) 

responsibility to" establish requirements for safe operation of such aircraft systems in national airspace 

systems." Section 333(c), of the Reform Act. 

Video Star Entertainment, LLC’s video UASs are rotorcrafts weighing less than 55 pounds including 

payload. (The DJI Phantom 3 Professional) They operate at a speed less than 50 knots and have the 

capability to hover and move in the vertical and horizontal plane simultaneously. UASs have an auto 

return to launch point when battery power is under 25%. The UAS will operate within the line of sight 

with in a protected flight area as described below and at 200 feet AGL or less with an observer located 

close at hand as to make voice communication possible. These operations will not create a hazard to 

users of the nation airspace, public nor the environment. 
Video Star Entertainment, LLC respectfully requests the grant of an exception to the following specific 

sections of the Title 14 Code Federal regulations a11owing it to operate lightweight UASs for commercial 

use, 

 14 CFR 21,subpart H, 14 CFR 45.23 (b) 14 CFR 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)&(b). 

Video Star Entertainment, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 

331-334, seeking relief from any current applicable FAR’s operating to prevent Video Star 

Entertainment, LLC future commercial use of small UASs to operate in the national airspace system 

(NAS) as described below. The Reform Act section 332 provides for such integration of civil unmanned 

aircraft into our NAS as it is in the public’s interest to do so. Video Star Entertainment, LLC’s UASs meet 

the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of

these UASs are expressly contemplated by the Reform Act. Video Star Entertainment, LLC would like to 

operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such aircraft. 

The Reform Act direct the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace before completion of the rule making required 

under Section 332 of the Reform Act. In making this determination, the Secretary of Transportation is 

required to determine which UASs do create a hazard to users of the NAS or the public or pose a threat

to national security in light of the following: 

- The UASs size, speed, weight and operational capability 

- Operation of the UASs in close proximity to airports and populated areas 

- Operation of the UASs within visual line of sight of the operator 

Reform Act 333(a). If the secretary determines that such vehicle “may operate safely in the national 

airspace system, the secretary shall establish requirements for the safe operation in national airspace” 

Video Star Entertainment, LLC video UASs are rotorcraft weighing less than 55 pounds including payload. 

(The DJI Phantom 3 Professional class) They operate at a speed less than 50 knots and have the 

capability to hover and move in the vertical and horizontal plane simultaneously. UASs have an auto 

return to launch point when battery power is under 25%. The UAS will operate within the line of sight 

with in a protected flight area as described below and at 200 feet AGL or less with an observer located 

close at hand as to make voice communication possible. These operations will not create a hazard to 

users of the nation airspace, public nor the environment. 

The very small nature of these UASs combined with the safe guards presented below, will allow for the 

safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow 

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

and altitudes they will operate approval of this exception presents no national security issues and 

absolutely minimal safety concerns which have been mitigated through our rigorous risk management 
process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions 

utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of 

aerial photography thereby benefiting the greater public's interest. Accordingly, the applicant requests 

that the FAA grant the requested exemption without delay. 

The following will be considered as the binding limitation on operations of Video Star Entertainment, 

LLC, 

1. Flights will only occur in the day time hours 

2. Flights will be operated in the line of sight of the operator (PIC) and Observer (VSO) 

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by 

manufacturers recommendations 

4. The UASs will weigh less than 55 lbs. 

5. Flights will be operated at 200 feet AGL or less. 

6. Crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO) 

7. Operator and crew will remain in contact during the flight operation 

8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons 

in the area 

9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce 

the chance of violating anyone's privacy 

10. All required FAA clearances will be obtained and distances from airports strictly observed. 

11. All UASs will have the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working. 

12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned to 

operate the UASs at a safe distance from the main fishing boat. 

13. Flights will only operate in VFR conditions. 

14. UASs have a function on the control to tell operator the distance away from the operator and its 

battery power remaining. 

15. Flight team will communicate by voice and the use of two-way radio if the area is too great to hear 

voice from all team members. 

16. UASs will be used to video private outings and functions, boating, jet skiing, kayaking, fishing trips 

and sporting events from a safe distance. 
17. When operating over or near water the UASs will be equipped with flotation devices so that 

recovery can be made as to prevent lithium battery exposure to the water table. 

14 CFR part 21Subpart H: Airworthiness Certificate 14 CFR 91.7(a}, 91.203(a)(l) Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation 

to FAR 91.203(a)(l). The size, weight and defined area of operations for Video Star Entertainment, LLC

UASs flights permits exception from Part 21 because they meet 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 USC 4470(f) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of 

weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. 

Video Star Entertainment, LLC meets or exceeds each of these elements 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights at or 

under 200 AGL to any UASs operator with a section 333 exemption. 

14 CFR 91.203(a & b) provides for carrying of civil aircraft certifications and registrations. These are 

inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by 

maintaining such certifications and registrations at Video Star Entertainment, LLC operations center. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable. 

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Video Star Entertainment, LLC 

operations center. 

The FAA has previously issued exemptions to this regulation in Exemptions No's 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Video Star Entertainment, LLC will 

only operate its UASs at or below 200AGL. They will be operated on a well defined AOR that has been 

carefully reviewed for hazards and minimizes the presence of any persons not essential for these 

operations. Flights will only be over private property that the owner has consented and all persons 

within this video area also give consent for this filming. Compared to flight operations of conventional 

and traditional aircraft or rotorcraft weighing far more than 50 lbs, operating below 500 AGL with 

flammable fuel UASs operations present a far smaller risk to the public. 
Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial

photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. 

Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of 

populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated

and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or 

almost erased. The granting of the use of these small UASs by Video Star Entertainment, LLC will give the 

people another avenue to express themselves and to have a video record to share with family and 

friends forever. 

Granting Video Star Entertainment, LLC the above exemption will allow for the expansion of UAS 

systems into the future for the safe conduct of free enterprise and the enjoyment of the masses. 

Video Star Entertainment, LLC respectfully requests the FAA grant its exception without delay. The FAA

has the authority to issue the exemption sought by Video Star Entertainment, LLC pursuant to the 

Federal Aviation Act, 85 P.L. 726 {1958) as amended {the ACT). 

Respectfully submitted, 

Jordan M Lister 

Owner 

Video Star Entertainment, LLC 

INTERESTS OF THE PETITIONER 

The objective is to expand a small video production business into Aerial Video and Photography Service

to provide high quality imaging for a variety of commercial and public uses, specifically targeting: 

- Wedding and Special Events coverage 

- Local news coverage 

- Video for Real Estate agents 

- Coverage of Sporting Events 

- Interviews of individuals 

UAS/AERIAL EQUIPMENT OF THE PETITIONER 

- DJI Phantom 3 Professional UASs 
Video Star Entertainment, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters 

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher 

than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In 

addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices)