December 1, 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: CONVOLUTION FILMS CREATIVE

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS SECTIONS 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 

2012 (PUBLIC LAW 112-95)

Daniel Bagbey

President

Convolution Films Creative

7603 Cornwall Rd

Richmond, VA 23229

804-314-1500

dbagbey@gmail.com

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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.......................................................................3

LIST OF INTENDED UAS’s................................................................................3

SUMMARY....................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER...............................................4

BASIS FOR PETITION......................................................................................5

NAME AND ADDRESS OF PETITIONER...............................................................6

THE EXTENT OF RELIEF AND THE REASONING...................................................6

HOW THE REQUEST WOULD BENEFIT THE PUBLIC AS A WHOLE .........................8

PRIVACY.......................................................................................................8

OPERATING PARAMETERS...............................................................................9

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER.................................10

CONCLUSION................................................................................................10

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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FSO Flight Safety Officer

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

LIST OF INTENDED UAS’s 

DJI Phantom 3 Standard with 2.7K Camera and 3-Axis Gimbal

DJI Inspire 1 Quadcopter with 4K Camera and 3-Axis Gimbal

DJI Inspire 1 Quadcopter with Zemuse X5 4K Camera and 3-Axis Gimbal

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SUMMARY

Convolution Films Creative seeks exemption from the requirements of 

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), 

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Convolution Films 

Creative to operate an Unmanned Aircraft System (UAS) for the commercial purpose of

conducting aerial video and photography, including imaging of construction sites, residential and 

commercial real estate, civil landscapes and events at secured and controlled sites within the 

conditions outlined by the FAA as required by Section 333.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear Sir or Madam,

Since 2011, Convolution Films Creative has provided their clients (which include

private sector businesses, public universities and private colleges, independent artists, and music 

venues) with video production services and targeted digital marketing strategies. 

Convolution Films Creative has a perfect client and employee safety record. The objective of 

Convolution Films Creative and our Unmanned Aircraft System operations is to provide an 

affordable, high-quality production system for a variety of governmental, commercial, public, 

and residential uses, specifically targeting

• Special event coverage

• Construction site documentation

• Architectural modeling

• Marketing and film production

• Economic development

The members of my staff that would comprise the flight team have safely flown small RC 

electric quadcopters recreationally for approximately 1 year without incident. These staff would 

also undergo further flight safety training before operating on a Convolution Films Creative 

flight crew. 

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BASIS FOR PETITION 

Petitioner, Convolution Films Creative, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the

Administrator to commercially operate UAS’s in the National Airspace System

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Convolution Films Creative operation of UAS’s meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Convolution Films Creative requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements

for maintenance that only apply to aircraft with an airworthiness certificate.

Convolution Films Creative submits that the requested relief is proper since an equivalent

level of safety will be ensured. Convolution Films Creative will use experienced personnel or

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and UAS Instruction Manual). Furthermore, Convolution Films Creative will 

document and maintain all maintenance records for the UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by Convolution Films Creative to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as

well as an airman medical certificate, and who has demonstrated, by meeting minimum flight 

hour and currency requirements, that the PIC is able to safely operate the UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

Convolution Films Creative seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the UAS does not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, Convolution Films Creative submits

that they will ensure that the UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS are in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and UAS Instruction Manual), and that the aircraft are in a

condition for safe flight. 

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Name and Address of the Petitioner.

The name and address of the Petitioner and point of contact is:

Daniel Bagbey

President

Convolution Films Creative

7603 Cornwall Rd

Richmond, VA 23229

8043141500

dbagbey@gmail.com

The Extent Of Relief And The Reasoning

1. Extent Of Relief Convolution Films Creative Seeks And The Reason Convolution Films 

Creative Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Convolution Films Creative submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the UAS unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the UAS in a manner consistent with the operations specifications as described in 

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures.

Further, Convolution Films Creative submits that all flights of the UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Convolution Films Creative 

business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Convolution Films Creative Seeks And The Reason Convolution Films 

Creative Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow Convolution Films Creative to determine that the DJI Phantom 3 UAS are in

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the

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operating documents (i.e., Convolution Films Creative Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3 Instruction Manual).

Convolution Films Creative seeks the requested relief because the DJI Phantom 3 UAS do not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

Convolution Films Creative will ensure that the DJI Phantom 3 UAS are in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly Maintenance

Log, and DJI Phantom 3) prior to every flight, and further, determine that the aircraft are in

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Convolution Films Creative Seeks And The Reason Convolution Films 

Creative Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Convolution Films Creative seeks the requested relief because the UA’s altimeter may be 

set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the UAS are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures 

that a ground level pressure setting will be established prior to each flight, and provides the PIC 

with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Convolution Films Creative Seeks And The Reason Convolution Films 

Creative Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 23 minutes. Convolution Films Creative seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the UAS will severely constrain 

the practicality of any aerial video or still photo flight operations that Convolution Films Creative 

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the UAS, the operating 

documents, and Convolution Films Creative’s proposed operating limitations, ensure that 

Convolution Films Creative will safely operate the battery powered UAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery 

power to fly for a total duration of 23 minutes.

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5. Extent Of Relief Convolution Films Creative Seeks And The Reason Convolution Films 

Creative Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to

aircraft with an airworthiness certificate, Convolution Films Creative requests relief from

these Sections because the UAS do not require airworthiness certificates. As set

forth more fully below, the UAS meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, Convolution Films Creative will

use trained technicians to perform maintenance, alterations, or preventive maintenance on the

UAS using the methods, techniques, and practices prescribed in the UAS operating documents

(i.e., the Convolution Films Creative Aerial Operations Manual, Monthly Maintenance Log,

and UAS Instruction Manual). Furthermore, Convolution Films Creative will

document and maintain all maintenance records for the UAS. 

How The Request Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Convolution Films 

Creative to safely, efficiently, and economically perform aerial video and photography of events,

construction sites, and real estate over certain areas of the United States.

The use of UAS’s will provide significant benefits to the economy and spur innovation and new 

advancements within the infrastructure and production industries alike. Notably, the benefits of 

Convolution Films Creative’s proposed operation of the UAS will be realized without 

implicating any privacy issues. 

Privacy 

All flights will occur over private or controlled access property with the property owner's

prior consent and knowledge. Images taken will be of individuals who have also

consented to being filmed or otherwise have agreed to be in the area where aerial

photography will take place.

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OPERATING PARAMETERS

Convolution Films Creative will adhere to the following operating parameters when operating 

UAS pursuant to a grant of the requested exemption:

1. The UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour), at an 

altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute 

miles. All operations will be conducted during the day under visual meteorological 

conditions.

2. All operations will be conducted in accordance with an Authorization (“COA'').

3. All operations will use a pilot-in-command (“PIC”), a visual observer ("VO"), and a Flight 

Safety Officer (“FSO”), and the UAS will remain within the visual line of sight of the PIC or 

the VO at all times. The PIC will maintain VLOS capability and the ability to communicate 

verbally with the VO at all times.

4. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot 

certificate, as well as an FAA airman medical certificate or a valid U.S. driver's license. The 

PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.

5. Convolution Films Creative will ensure prior to operation that the PIC has demonstrated the 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency will be logged in a manner consistent with 14 C.F.R. § 61.51(b).

6. Convolution Films Creative’s operating documents will be accessible during UAS operations 

and made available to the Administrator upon request.

7. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has been 

performed and the U AS is found to be in a condition for safe flight.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting further operations under this exemption.

9. Convolution Films Creative will follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements, as well as safety bulletins, for the 

aircraft and aircraft components.

10. The PIC will land the aircraft in the event of unpredicted obstacles or emergencies, and will 

yield to all manned aviation activities.

11. Convolution Films Creative will register and mark its UAS in accordance with 14 C.P.R. 

parts 47 and 45. 

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SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Should the FAA determine that publication in the Federal Register is required, Convolution 

Films Creative offers the following summary pursuant to section 11.81 of the FAA's rules:

Petitioner: Convolution Films Creative

Sections of 14 C. FR. Affected: 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate unmanned aerial systems for the commercial purpose of conducting 

aerial video and photography, including imaging of construction sites, residential and 

commercial real estate, and special events.

CONCLUSION 

As demonstrated above, the UAS operations Convolution Films Creative has proposed in this 

petition for exemption will garner significant public benefits while presenting minimal safety 

risks. Convolution Films Creative’s petition satisfies the criteria provided in Section 333 of the 

Reform Act of 2012, including size, weight, speed, operating capabilities, proximity to airports, 

populated areas, operation within visual line of sight and national security, and is substantially 

similar to previous petitions the FAA has granted, meriting a summary grant of exemption. 

Convolution Films Creative respectfully requests that the FAA grant this petition to enhance 

Convolution Films Creative’s ability to provide it’s clients greater value and expand the 

capabilities of the industry. 

Thank you for your time and consideration. Please do not hesitate to contact the petitioner with 

any concerns about this document. dbagbey@gmail.com or (804) 314 - 1500. 

Sincerely,

Daniel Bagbey

Convolution Films Creative

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