January 15, 2016 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Petition CP PRODUCTIONS LLC for Exemption Pursuant to Section 333 of the 

FAA Reform Act 

Petitioner's Name and Address: 

CP PRODUCTIONS LLC 

Owner: Herbert C Stackhouse 

166 Hurffville Cross Keys Rd. 

Sewell, NJ 08080 

856-449-7349 

chris@cpwebmarketing.com 

To whom it may concern: 

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

and 14 C.F.R. Part 11, CP PRODUCTIONS LLC operator of Small Unmanned Aircraft Systems 

("UASs") equipped to conduct aerial photography and videography, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation 

of UASs, so 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 333.1 

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

unmanned and relatively inexpensive UAS under conditions in airspace that is 1) limited 2) 

predetermined and 3) controlled. The proposed exemption, if granted, would allow 

CP PRODUCTIONS LLC to conduct commercial operations of UASs meeting or exceeding all of 

the operational and safety requirements Congress has set forth in Section 333. 

CP PRODUCTIONS LLC plans to use the capabilities of UASs to offer a multitude of services, 

including: 

- Insurance surveys and inspections 

- Real Estate Photography and presentation 

- Construction site inspections and monitoring 

-Event Photography/Videography 

- Aerial filmmaking and photography 

-Aerial surveying of local water supply to the community 

- Agriculture and Livestock monitoring 
Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", 

provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft 

Systems (UAS) operations in the National Airspace System ("NAS"). Section 333(a) states that 

the FAA "shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the (comprehensive) plan and rulemaking 

required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act." In 

Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited 

operation authorization" if several factors are met. Petitioner meets all requirements to permit 

FAA approval of commercial UAS operations. 

The name and address of the applicant are: 

Name: 

Owner: 

Address: 

Phone: 

Email: 

CP PRODUCTIONS LLC 

Herbert Stackhouse 

166 Hurffville Cross Keys Rd. 

Sewell, NJ 08080 

856-449-7349 

chris@cpwebmarketing.com 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 61.315(c) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121Page 3 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401- 91.417) 

UASs are oftentimes seen as superior to helicopters due to the lesser cost of equipment, 

the reduction of personnel needed to operate equipment, reduced noise levels and zero 

emissions into the environment. In addition to providing cost savings and having little to 

no impact on the environment, UASs provide enhanced safety. These factors are 

beneficial for, and in the best interest of, the public. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

Petitioner is requesting an exemption to enable CP PRODUCTIONS LLC to operate a DJI Inspire 1 

UAS, as well as a DJI Phantom 3. Both always upgraded to latest version firmware, equipped 

with a 3 axis Zen muse camera gimbal, which uses a High-Def video camera that can capture up 
to 4K (4096x2160p) video and 12M pixel photos. Both of these UAS vehicles have a built-in 

capability to limit 1) the height it flies above the ground and 2) the radius of the distance it flies 

from the operator. The OJ I Inspire 1 and Phantom 3 also has the failsafe function of the 

autopilot system, which means, when the communication between the Main Controller and the 

transmitter is disconnected, the outputs of all command sticks from controller will go to the 

center position. If the GPS signal is good enough, the system will automatically trigger Return to 

Home and will land safely. Both of these aircrafts have a total gross weight of less than 7 

pounds when fully equipped. 

A pre-flight inspection will be performed by the PIC in accordance with the factory instruction 

manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make 

sure that the compass, gyro and acceleration values are within specs, positive GPS locks are 

secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in. 

The UAS will be maintained in accordance with the manufacturer's instruction manual and only 

manufacturer's authorized replacement parts will be used. 

FCC Information 

The OJ I Inspire 1 and Phantom 3 transmitters used for controlling the UAS comply with part 15 

of the FCC rules. Operation is subject to the following two conditions: (1) This device may not 

cause harmful interference, and (2) this device must accept any interference received, including 

interference that may cause undesired operation. 

The radio transmitters of the DJIInspirel and Phantom 3 used for controlling the UAS is 

wireless technology which has been tested and found to be compliant with the applicable 

regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range. 

Antenna Separation Distance 

When operating the OJ I Inspire 1 or Phantom 3 transmitter, the PIC will maintain a separation 

distance of at least 5 em between his body (excluding fingers, hands, wrists, ankles and feet) . 

and the antenna to meet RF exposure safety requirements as determined by FCC regulations. 

Pilot in Command and Observer Qualifications and Duties 

The PIC will maintain at least a Sport Pilot Certificate and a current State issued driver's license, 

plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the type of UAS 

utilized in operations. 

The PIC will have at least 30 hours flying Radio Controlled 

Model Aircraft, of which, 10 hours will be flying UASs. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include 

all preflight preparation and inspection, in flight operation, post flight requirements, and all 

procedures including but not limited to: 

., 
• Safe in flight operations 

• Risk evaluation 

• Current weather conditions for safe flight 

The Observer must have the visual acuity to observe the UAS and be able to communicate 

clearly with the PIC. The Observers duties are: 

• Warning the PIC of any impending obstacles in the flight path of the UAS. 

• Warning the PIC of any deviations in the planned flight path of the UAS. 

• Warning the PIC should any unauthorized personnel appear in the area of the planned 

flight. 

The Observer will have the authority to order the PIC to terminate the flight should he feel the 

flight cannot be conducted safely. 

General Operating Standards 

• CP PRODUCTIONS LLC will only operate its UAS in line of sight of a pilot and/or 

observer and will operate at sites that are a 'sufficient distance' from populated areas. 

Such operation will insure that the UAS will "not create a hazard to users of the national 

airspace system or the public." 

• Before an operation of a UAS within SNM of an airport with a control tower, the 

control tower will be called to gain permission to operate the UAS. The PIC will give the 

position, altitude and the times the UAV will be operated. The UAS will not be operated 

at an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 

1000 foot ceiling. 

• Before an operation of a UAS within SNM of a non-tower controlled, airport operators 

will be notified and the PIC will give the right of way to avoid flying in the proximity of 

full-scale aircraft. At no time will the UAS be operated within the final approach course. 

and the takeoff course of any runway. The UAV will not be operated at an altitude of 

over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. 

• Maximum flight time for each operational flight will be 18 minutes. 

• Flights will be terminated at 30% battery power reserve should that occur prior to the 

18 minute limit. 

• The UAV will be programmed so that it will not be operated at an altitude of more 

than 200 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned. 

• Minimum crew for each operation will consist of the UAS Pilot, and Visual Observer. 

., 
• The UAV operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbals). 

• The UAS will operate at speeds much less than 87 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the UAV and the restricted sterile environment within which 

they will operate, our UAV operations adhere to the Reform Act's safety requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel. The UAS operates at lower altitudes with no people on board and 

will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this 

offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. The benefits of reduced cost and improved quality of presentation 

from the UAS over manned aircraft will be valuable to and benefit many buyers and sellers of 

real property, farmers and ranchers, and local city officials to monitor our local water supply. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

CP PRODUCTIONS LLC requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the UAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DJIInspire1 and Phantom 3 under either 

or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations 

to show compliance with the airworthiness regulations including flights to show compliance for 

issuance of type and supplemental type certificates, flights to substantiate major design 

changes, and flights to show compliance with the function and reliability requirements of the 

regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. The aircraft will not carry persons or 
property, will not carry fuel, and will only fly under strict operational requirements. Combined 

with the UAS's light weight, being constructed primarily of carbon fiber and plastic, we propose 

that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of safety 

outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" on the fuselage, where the PIC (Pilot In Control), VO (Visual Observer) and 

others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. All aircraft operated in accordance with the granted exemption will be identified 

by serial number, registered in accordance with 14 CFR part 47, and have identification 

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large 

as practicable. 

14 CFR 61.315 What are the limits and privileges of my sport pilot certificate, 

61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

61.315 subparagraph (c) does not allow a person who holds a Sport Pilot Certificate to act as a 

Pilot in Command in furtherance of a business. 61.113 provides that no person that holds a 

Private Pilot certificate may act as Pilot in Command of an aircraft for compensation or hire. 

Subparagraph (b) allows a private pilot to act as pilot in command 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. Our proposed operations require that the PIC must hold at least a Sport Pilot Certificate . 

with a current valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal government and is actively training towards earning a 

Private Pilot Certificate with a Class Ill Medical issued by the FAA. Since the aircraft cannot 

carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business and are entitled to relief from 

61.315 (c) in consideration of the guidelines set forth in the granted exemptions of previous 

petitioners in similar circumstances. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 
14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, 

the documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 

UAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, 

or preparing for, flight, and ready for presentation for any governing official upon request. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. Although the DJIInspire 1 is 

capable of duel/linked controls, CP PRODUCTIONS LLC will be operating with a single remote 

controller. 

91.119 Minimum safe altitudes: 

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it 

would be necessary to operate closer than 500 feet to the items listed. Operations will only be 

flown over property or persons where permission has been obtained and careful preplanned 

flight path has been performed. The aircraft will be operated at a low altitude allowing, if a 

power unit fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, 

vehicles and structures is minimal compared to manned aircraft, which should be considered in 

granting the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 200 feet 

AGL and will not need to maintain cruising altitudes in order to prevent conflict with other 

aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the UAS on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The UAV is battery operated and the maximum 

duration of flight from a single battery charge is 18 minutes with a 30% reserve. Since the 
aircraft will never fly more than 0.263 NM from the point of intended landing, a full battery 

charge at launch will ensure that we meet the reserve energy requirement of this paragraph. 

We request an exemption to the word "fuel" and ask for an equivalent interpretation with the 

word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47 

pounds, the UAS is too small to carry documentation, does not have an entrance, and is not 

capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the 

intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA 

will be with the crew at the ground control station and available for inspection upon request. In 

order to identify the aircraft, we propose that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via placard containing the 

following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 

45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance 

and inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition conduct detailed inspections after every two hours of flight. Maintenance performed 

by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. The PIC 

will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAS 

CP PRODUCTIONS LLC will be using the UAS in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer 

more efficient and safer benefits over the use of full-sized manned aircraft for aerial 

photography, advanced agriculture monitoring, film and still photography, real estate 

marketing, inspection of buildings and transportation infrastructure 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS 

carrying no passengers or crew creates a much greater margin of safety for the pilots, crew and 

general public. 
By granting CP PRODUCTIONS LLC's requested exemptions, the FAA will help drive development 

of safe and successful commercial UAS operations and will advance the public knowledge base 

for such operations. CP PRODUCTIONS is committed to promoting the UAS research efforts of 

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial 

UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has 

good cause to grant this Petition. 

Conclusion 

As pointed out in this application, the DJIInspirel and Phantom 3, which our company would 

use, under authorization by the US DOT-FAA, are small, light-weight devices operated within 

the line of sight of the Pilot-in-Command (PIC), less than 200 feet above the ground and outside 

5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation 

activities, unless the air traffic control authorities (ATC) have been notified and have authorized 

each flight within a radius of this distance. 

The DJIInspirel and Phantom 3 both have been proven capable for controlled flight. Both are a 

UAS offered for general sale on the market around the world and have often been used as 

Model Aircraft in the USA. 

We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 

112-95, 2014, have already provided you with the assurances on the airworthiness of UAS such 

as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and CP 

PRODUCTIONS LLC should be permitted to conduct small UAS operations in accordance with its 

manuals and all other operating parameters deemed necessary and appropriate by the FAA. 

The submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some UAS may be used for legitimate 

commercial activities and under reasonably safe conditions. 

Signed 

~k£~ Herbert Stackhouse 

CP PRODUCTIONS LLC