U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 1

Anthony Oyedeji

Full Fledge Entertainment, LLC

3603 Chenevert St. #401

Houston, Texas 77004

p: (832) 303-0396

e: fullfledgeent@gmail.com

May 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Full Fledge Entertainment, LLC for Grant of Exemption Pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012.

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of 

the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of 

the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the 

petition of FLYING CAM INC

To Whom It May Concern:

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

Reform Act), Full Fledge Entertainment, LLC, herein referred to as "FFE," hereby 

applies for an exemption from the Federal Aviation Regulations (FARs) listed below to 

allow operation of our Unmanned Aircraft Systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA), so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

The requested exemption would permit FFE to pursue its commercial interests in 

providing services to clients using small advanced UAS in the following areas:

• Video/Film Production

• Marketing

• Surveying

• Industrial Inspection

• Special Events
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 2

The petitioner has provided the following information to support its request for an 

exemption:

• Attachment1_AeriCam X6--Flight Check List.pdf

• Attachment2_WooKong-M_Quick_Start_Guide_v1.14_en.pdf

• Attachment3_7c-manual.pdf

• Attachment4_Inspire_1_Safety_Guidelines_en.pdf

• Attachment5_Inspire_1_Maintenance_ManualV1.0_en.pdf

• Attachment6_Inspire 1 Checklist

Title 14, Code of Regulations sections from	which	exemption	is	requested:

Part 21; 45.23; 61.113(a) & (b); 61.133; 91.7(a); 91.9(b); 91.109; 91.119; 91.121;

91.151(a); 91.203(a) & (b); 91.407 – 91.417.

Unmanned Aircraft System

UAS are often more practical than helicopters as aerial video and photography 

gathering platform due to the size, purchase cost, operating cost, reduced noise and as 

such, has a much smaller environmental impact which promotes environmental and 

public safety.

FFE is petitioning for an exemption to operate an Aericam X6 and a DJI Inspire 1. 

The Aericam X6 and DJI Inspire 1 offer an advanced built-in gimbal system, can carry 

an Ultra High Defenition (UHD) camera, has GPS, live point of view camera feed, flight 

telemetry, monitors and controls for power levels, height and distance limits, a No-Fly 

Zone feature to exclude it from operations within designated Class B, C and D airspace, 

and a return to home function. Both UAS platforms have failsafe functions that are 

triggered in the event that communication is lost between the UAS and the main 

controller transmitter. At that time, the UAS will return to its point of takeoff and land 

safety. If the connection is restored, the PIC can regain control of flight and land 

manually.

These specifications meet with the Model Aircraft Operating Standards as set 

below:

• The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and 

will operate at sites that are ‘sufficient distance’ from populated areas within the sterile 

area described in the FOPM. Such operations will ensure that the UAS will “not create 

a hazard to users of the national airspace system or the public.”

• When flying the UAS within three (3) miles of an airport, airport operators will be 

notified and the operator will give the right-of-way to avoid flying in the proximity of 

full-scale aircraft.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 3

• Maximum flight time for each operation will be 30 minutes.

• Minimum crew for each operation shall consist of: UAS pilot, a visual UAS observer, 

and/or the camera operator.

• The UAS operated by the petitioner weighs less than 55 pounds, including all payload 

(i.e. camera, lens, and stabilized gimbal).

• The UAS will operate at speeds of no more than 50 knots, can hover, and 

can simultaneously move vertically and horizontally. Given the small size of the UAS 

and the restricted sterile environment in which it will operate, FFE's operations adhere 

to the Reform Act’s safety requirements. The fact that FFE's more than two years of 

successful UAS piloting experience demonstrates our high regard for safe operations 

with an understanding of FARs, pre-flight inspections, knowledge of operations and 

differences in airspace classifications, maintenance and repair, as well as being trained 

to high safety standards.

Under the requested exemption, FFE ensures all operators have completed UAS 

education and training programs including applicable regulations, guidance documents, 

and safe operations procedures.

We respectively request exemption under Section 333 to enable FFE to operate 

efficient, limited, low-risk commercial UAS operations for the activities stated respecting 

at all times the space and privacy of citizens and property while keeping airspace safe.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

FFE requests an exemption from the following FARs as well as any additional 

regulations that may technically apply to the operation of our UAS:

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 

Aericam X6 and DJI Inspire 1 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.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 4

(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, property, or fuel, and will only fly under strict operational 

requirements. Combined with the UAS lightweight, being constructed primarily of 

carbon fiber, fiberglass, 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.

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.

Our UAS do not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA.

61.113(a) and (b). Private pilot privileges and limitations: Pilot in Command; and 

61.133 Commercial pilot privileges and limitations.

The regulation provides that no person who 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. 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.

The petitioner requests relief in order to facilitate the utilization of an experienced 

UAS operator with the addition of a trained observer. All pre-flight inspection, 

maintenance and flight logs will be saved and made available to the FAA and Secretary 

of Transportation (SoT) for review; with the purpose of safely integrating civil UAS 

operation in the National Airspace System.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 5

91.7(a). 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.

91.9(b). 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.

91.109. Flight Instruction; Simulated instrument flight and certain flight tests.

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

for flight instruction unless that aircraft has fully functioning dual controls." The UAS 

System ground-based control station consists of a hand-held radio transmitter and while it 

does not offer a second set of "controls", both the student and instructor can, and will, 

operate the single set of controls simultaneously. With both student and instructor having 

"hands-on" the controls during flight, this technique meets the intent of 91.109 and 

provides an equivalent level of safety.

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 videography, photography or survey of persons, vessels, 

vehicles or structures, it would be necessary to operate closer than 500 feet to the items 

listed. 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated closer 

than 500 feet to essential persons, or objects that would not be possible without additional 

relief. The petitioner requests modification, waiver or exemption and clarification 

concerning the terms “congested areas” and “densely populated”.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 6

FFE requests a waiver for this condition to allow for reasonable and responsible 

flights. Operations will only be flown over property or persons where permission has 

been obtained and careful pre-planning has been performed. 

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.

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) CFR 91.121 is 

inapplicable since the UAS do not have an altimeter and instead utilize electronic GPS 

with a barometric sensor for altitude information.

An Above Ground Level (AGL) measurement is transmitted via radio from the 

UAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout.

91.151(a). 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.

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS 

LLC) prior relief has been granted for manned aircraft to operate at less than the 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 

for daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the PIC. The UA batteries provide approximately 25 minutes of powered flight. 

Information provided in the operating documents discusses procedures regarding 

remaining battery power management. Those documents contain a condition in which the 

PIC will initiate a landing procedure when battery remaining reaches a specified level. 

Given the limitations on proposed operations and the location of those proposed 

operations, The FAA found that a reduced minimum power reserve for flight in daytime 

VFR conditions was reasonable.

We feel the intention of this paragraph is to provide an energy reserve as a safety 

buffer for delays to landing. The UAS is battery operated and the maximum duration of 

flight from a single battery charge is 22 minutes with a 20% reserve. A full battery charge 

at launch will ensure that we meet the reserve energy requirement of this paragraph.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 7

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 its maximum 

gross weight, 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 located with the crew at the ground control station and 

available for inspection upon request.

91.407- 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. 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) FFE propose to 

inspect and ensure that the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the requirements for 

maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected.

It is our intention that the PIC performs 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. The manufacturer or 

their designated repair facility will perform all other maintenance. 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.
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 8

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3, Conditions and 

Limitations section, and believes that the procedures specified therein are reasonable and 

will be utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist will be developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure prone components. These documents will be made available to the FAA and SoT 

to assist in future implementation of safety standards and regulations. The petitioner will 

only operate the UAS over designated properties with the owner’s consent. Flight plans 

will be predetermined to limit the UAS flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight obstacles prior 

to operating the UAS.

FFE requests that in a manner similar to reference 3, may be allowed to operate 

within 5 miles of an airport provided that. 

“The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UA may not operate within 5 nautical miles of the geographic center 

of a non- towered airport as denoted on a current FAA published aeronautical chart 

unless a letter of agreement with that airport’s management is obtained, and the operation 

is conducted in accordance with a NOTAM as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the Administrator 

upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but FFE is

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within class B airspace are not requested 

due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial 

videography is a valuable marketing tool that can lead to increased commerce. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risks. The petitioner will provide clients with photographic data 

for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual 

observer will be utilized. Flight data including UA flight time, Control Unit operation 

time, incident, accident, and details concerning any deviations from normal operations 

will be available to FAA for use in collecting data regarding the use of UAS as part of 
U.S. Department of Transportation 

Full Fledge Entertainment, LLC – Petition for Exemption - FAA Section 333 Page 9

this application. This data may be submitted to FAA via traditional means or other means 

as required.

Conclusion

FFE is requesting this exemption for the purposes of aerial photography, 

cinematography, videography, inspections and other data collection operations. The 

reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to 

capitalize on opportunities as they may arise in the future without the long turnaround 

time associated with additional exemptions. The petitioner's business hopes to offer UAS 

services to individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business. The primary purpose of seeking this 

exemption is to obtain the capability to offer the aforementioned services while 

remaining in compliance with the FAA.

We thank you for your prompt consideration of our requested exemptions. 

Should you have any questions, or need additional information to support the requested 

exemptions, please feel free to contact the undersigned. 

Yours truly,

Anthony Oyedeji, Owner

Full Fledge Entertainment, LLC

 Anthony Oyedeji