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Brian Kulpa

Brian Kulpa Photography LLC

3924 Kentwood Ct.

Reno, NV 89503

(413) 464-1966

brian@briankulpaphotography.com 

December 4, 2015

U.S. Department of Transportation Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590

RE: Amendments to Grant of Exemption No. 12446 Regulatory Docket 

No. FAA−2015−0820

Dear Sir or Madam,

On August 12, 2015 the Federal Aviation Administration (“FAA”) granted 

an exemption from certain provisions of the Federal Aviation Regulations 

(“FAR”) pursuant to Section 333 of Public Law 112-95 to petitioner Brian 

Kulpa Photography permitting operation of a DJI Inspire 1 small unmanned 

aerial system (“sUAS”) for the purposes of conducting aerial photography, 

videography, surveying, cinematography, inspections and search and rescue.

Please see Grant of Exemption No. 12446 (the “Grant of Exemption”) and 

Brian Kulpa Photography’s petition for exemption, docket no. FAA-2015-

0820, the terms of both are attached separately from this amendment. Brian 

Kulpa Photography has submitted all necessary paperwork to the FAA in 

regards of Aircraft Registration (AC Form 8050-1) and Aircraft Bill of Sale 

(AC Form 8050-2) as Brian Kulpa Photography LLC, which was formed on 

October 8, 2015, all documentation, including the Articles of Organization, 
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are on file with the FAA. Brian Kulpa Photography now submits this request 

to amend the Grant of Exemption as follows:

A) To expand the scope of the Grant of Exemption to permit operation of 

covered small-unmanned aerial systems (“sUAS”) in gathering aerial 

photography and videography for television/newsgathering, closed set 

motion picture filming, real estate, and golf courses. 

. Additional Scope of Use

Brian Kulpa Photography requests amendment of the Grant of Exemption to 

permit use of covered sUAS for the purposes of photography and 

videography in the categories of television/newsgathering, closed set motion 

picture filming, real estate, and golf courses. The public benefits of a grant 

of exemption for these uses are evident from the Grant of Exemption. 

Regular helicopters are, except as provided in Section 91.119, not allowed to 

fly less than 500 feet AGL. sUAS on the other hand are best when flown 

between 50 and 275 feet AGL and in fact the best video quality is 50 to 175

feet. A manned helicopter could cause very serious damage to persons or 

property on the ground in a system failure, most notably the pilots and 

passengers inside a manned helicopter. A sUAS on the other hand weighing 

in at approximately seven pounds would not be nearly as hazardous. A

standard helicopter is normally larger than an automobile whereas the sUAS 

is drastically smaller, in this case weighing less than ten pounds. It is 

substantially safer for the public to have a sUAS accomplish the job of aerial 

photography and videography than a manned helicopter just based on size 

alone. Further, there has been no change in the conditions and reasons 

relative to the public interest and safety that were the basis for granting the 
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original exemption.

For the purposes of television/newsgathering, a sUAS may be an exceptional 

tool for journalists. It will provide a different perspective of what is being

covered in a particular story to educating the public on unmanned aerial 

systems. This would allow the journalist to provide enhancing, accurate 

distribution of newsworthy and relevant information to all citizens, while 

educating them about unmanned aerial systems in the process. The public 

looks to news outlets as its source of information about events happening in 

the region, nationally, and globally. By using sUAS to achieve a different 

perspective, much more safely than a manned helicopter that is carrying a 

fuel load, this would allow the citizens to engage in the topic being covered 

by the journalist in a different perspective than otherwise notably observed 

from the ground. 

This also ties into closed set motion picture filming, real estate, and golf 

course aerial photography and videography. It is much safer for all persons 

and property involved on a closed set motion picture filming, real estate, and 

golf course to be using a sUAS instead of a helicopter because a fuel load is 

not being carried, instead a battery pack is used as the sUAS power source. 

When being used in in these situations, you have to factor in the terrain in 

which you are filming. The use of a sUAS would be able to maneuver much 

safer to the ground based on size alone compared to the size of a helicopter. 

The use of sUAS benefits the public by providing a safer environment and 

educational platform when gathering aerial photography and videography 

for television/newsgathering, closed set motion picture filming, real estate, 

and golf courses. 
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I, Brian Kulpa, respectfully submit this amendment to the Grant of 

Exemption No. 12446, previously granted to Brian Kulpa Photography. 

Brian Kulpa

Brian Kulpa Photography LLC

3924 Kentwood Ct.

Reno, NV 89503

(413) 464-1966

brian@briankulpaphotography.com