January	2,	2016

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	form:	14	CFR	Part	21;	14	CFR 45.23	(b);	14	CFR	61.113	

(a)	&	(b);	14	CFR	91.7	(a);	14	CFR	91.9	(b)	(2);	14	CFR	91.103	(b);	14	CFR	91.109;	

14	CFR	91.119;	14	CFR	91.121;	14	CFR	91.151	(a);	14	CFR	91.203	(a)	&	(b);	14	CFR	

91.405	(a);	14	CFR	91,407	(a)	(1);	14	CFR	91.409	(a)	(2);	14	CFR	91.417	(a)	&	(b).

To	Whom	It	May	Concern:

In	pursuant	with	section	333	of	the	FAA	Modernization	and	reform	Act	of	2012	and	

14	C.F.R.	Part	11,	I,	Jeff	Caprine,	DBA	321	Fish	On,	an	operator	of	a	small	Unmanned	

Aircraft	System	(sUAS)	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	to	allow	commercial	operations	of	it’s	sUASs,	so	long	as	such	

operators	are	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	

be	established	by	the	FAA	as	required	by	section	333.

As	described	more	fully	below,	the	requested	exemption would	permit	the	

operation	of	small,	unmanned	and	relatively	inexpensive	sUAS	under	controlled	

conditions	in	airspace	that	is	limited,	predetermined,	controlled	as	to	access	and	

would	provide	safety	enhancements	to	the	already	safe	operations	within	

commercial	use.	Approval	of	this	exemption	would	thereby	enhance	safety	and	

fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	

“establish	requirements	for	the	safe	operation of	such	aircraft	system	in	the	national	

airspace	system.	“ Section	333(c)	of	the	Reform	Act.”

Information	Supporting	this	Petition	as	Specified	in	14	C.F.R.	§11.81

(a)	Your	name	and	mailing	address	and,	if	you	wish,	other	contact	information	such	

as	a	fax	number,	telephone	number,	or	e-mail	address.

The	name	and	address	of	the	applicant	is:

Name:	Jeff	Caprine

DBA:	321	Fish	On

Phone:	(714)	595-7903

Email:	321fishon@socal.rr.com

Address:	16751	Moody	Cir	#A.	

Huntington	Beach,	CA	92649
(b)	The	specific	section	or	sections	of	14	C.F.R.	from	which	Jeff	Caprine,	DBA	321	

Fish	On seeks	an	exemption

 14	CFR	Part	21	

 14	CFR	45.23	(b)

 14	CFR	61.113	(a)	&	(b)

 14	CFR	61.7	(a)

 14	CFR	91.9	(b)	(2)

 14	CFR	91.103	(b)

 14	CFR	91.109

 14	CFR	91.119

 14	CFR	91.121

 14	CFR	91.151	(a)

 14	CFR	91.203	(a)	&	(b)

 14	CFR	91.405	(a)

 14	CFR	91,407	(a)	(1)

 14	CFR	91.409	(a)	(2)

 14	CFR	91.417	(a)	&	(b)	

(c)	The	extent	of	relief	321	Fish	On seeks,	and	the	reason	321	Fish	On seeks	the	

relief,	321	Fish	On seeks	an	exemption	for	several	provisions	of	14	C.F.R.	Parts	21,	

45,	61,	and	91	to	the	extent	to	operate	small	UASs	to	record	aerial	video	for	

cinematographic	purposes.

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in passing	

Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	

Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may	

operate	safely	in	the	national	airspace	system	(NAS)	before	completion	of	the	

rulemaking	required	under	Section	332	of	the	Reform	Act.	In	making	this	

determination,	the	Secretary	is	required	to	determine	which	type	of	UAS’s	do	not	

create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national	security	

in	light	of	the	following:

 The UAS’s	size,	weight,	speed,	and	operational	capability;

 Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and

 Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator.

Reform	Act §	333	(a).	Lastly,	if	the	Secretary	determines	that	such	vehicles	“may	

operate	safely	in	the	national	airspace	system,	the	Secretary	shall	establish	

requirements	for	the	safe	operation	of	such	aircraft	in	the	national	airspace	system.”

The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	

exemptions.	This	statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	

as	the	term	is	defined	under	§40101	of	the	Act	that includes	sUASs,	from	the	

requirement	that	all	civil	aircraft	have	a	current	airworthiness	certificate.
The	Administration	may	grant	an	exemption	from	a	requirement	of	a	regulation	

prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections	44702-44716	

of	this	title	if	the	Administrator	finds	the	exemption	in	the	public	interest.	49	U.S.C.	

§44701(f)	See	also 49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91,203	(a)	(1).

14	C.F.R.	21	– Subpart	H	Certification	procedures	for	products	and	parts,	

Airworthiness	Certificate

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14	C.F.R.	21	– Subpart	H,	

which	states	the	certification	procedures	for	products	and	parts	as	well	as	

airworthiness	certificates.		The	sUAS	to	be	operated	hereunder	is	less	than	55	lbs.	

fully	loaded,	carries	neither	a	pilot	nor	passenger,	carries	no	explosive	material	or	

flammable	liquid	fuels, and	operates	exclusively	within	a	relatively	small-secured	

area.	Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly	

controlled	and	monitored	by	the	Pilot/”Operator”	and	the	visual	observer.	These	

safety	enhancements,	which	already	apply	to	civil	aircraft	operated	to	conduct	aerial	

videography	and	photography	services,	provide	a	greater	degree	of	safety	to	the	

public	and	property	owners	than	conventional	operations	conducted	with	

airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	

application	of	these	same	criteria	demonstrates	that	there	is	no	threat	to	national	

security	posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	limited	operational	

area,	lack	of	explosive	material	or	flammable	liquid	fuels,	and	inability	to	carry	a	

substantial	external	load.

14	C.F.R.	§45.23	(b).	Marking	of	the	Aircraft

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14	C.F.R.	§45.23,	which	

discusses	the	display	of	marks.	Specifically,	section	§45.23	states,	“(a)	each	operator	

of	an	aircraft	must	display	on	that	aircraft	marks	consisting	of	the	Roman	capital	

letter	“N”	(denoting	United	States	registration)	followed	by	the	registration	number	

of	the	aircraft.	Each	suffix	letter	used	in	the	marks	displayed	must	also	be	a	Roman	

capital	letter	(b)	when	marks	include	only	the	Roman	capital	letter	“N”	and	the	

registration	number	is	displayed	on	limited,	restricted	or	light-sport	category	

aircraft	or	experimental	or	provisionally	certified	aircraft,	the	operator	must	also	

display	on	that	aircraft	near	the	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	

letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	“limited,’	

“restricted,”	“light-sport,”	“experimental,”	or	“provisional,”	as	applicable.

Jeff	Caprine,	DBA 321	Fish	On,	will	need	exemption	from	this	regulation	due	to	the	

small	size	of	the	aircraft	and	that	there	is	no	cabin,	cockpit,	or	pilot	station	for	the	

aircraft.	The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	marked	on	

its	fuselage	as required	by	§45.29	(f)	where	the	pilot,	observer	and	others	working	

with	the	UAS	will	see	the	identification	of	the	UAS	as	“Experimental.”
14	C.F.R.	§61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	

Command.

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14	C.F.R.	§61.113,	which	

discusses	private	pilot	privileges	and	limitations	for	the	pilot	in	command	(PIC).

Jeff	Caprine,	DBA	321	Fish	On,	is	seeking	exemption	from	this regulation,	because	

321	Fish	On believes	that	there	is inconclusive	evidence	that	a	person	with	a	private	

pilot	certificate	can	successfully	maneuver	a	sUAS	without	first	hand	flight	

experience	with	the	particular	sUAS.	In	fact,	having	a	private	pilot	license	does	not	

automatically	ensure	competence	at	flying	a	sUAS	in	3rd person	view	as	required	to	

properly	operate	a	sUAS	with	the	required	line	of	sight.	The	area	of	operation	is	

limited	and	all	flights	are	planned	and	coordinated	in	advance.	Therefore,	321	Fish	

On believes	that	our	own	flight	training	with	the	sUAS	will	be	more	than	

satisfactory.	

14	C.F.R.	§91.7(a):	Civil	Aircraft	Worthiness.

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14.	C.F.R.	§91.7(a),	which	the	

regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	

airworthy	condition.	As	there	will	be	airworthiness	certificate	issued	for	the	aircraft,	

should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for	

determining	airworthiness.	Given	the	size	of	the	aircraft	for	maintenance	and	use	of	

safety	checklists	prior	to	each	flight,	an	equivalent	level	of	safety	will	be	provided.

14	C.F.R.	§91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	14.	C.F.R.	§91.9	(b)	(2),	which	in	

section	§91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.	registered	civil	

aircraft...	(2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	

§21.5	of	this	chapter,	unless	there	is	available	in	the	aircraft	a	current	approved	

airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material,	markings,	and	

placards,	or	any	combination	thereof.	

Jeff	Caprine,	DBA	321	Fish	On is	seeking	exemption	from	this	regulation	due	to	the	

sUAS	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	manual	on	

the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	because	there	is	no	

room	or	capacity	to	carry	such	an	item	on	the	aircraft.

The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the	

ground	control	point	where	the	“Pilot/”Operator”	“	flying	the	sUAS	will	have	

immediate	access	to	it.	The	FAA	has	issued	the	following	exemptions	to	this	

regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167,	

10167A,	10602,	32827,	and	10700.
14	C.F.R.	§91.103	– Preflight	Actions

Jeff	Caprine,	DBA	321	Fish	On,	is	seeking	exemption	from	14	C.F.R.	§91.103,	which	

states	that	each	pilot	in	command	shall,	before	beginning	a	flight,	become	familiar	

with	all	available	information	concerning	that	flight.	This	information	must	include:	

(a)	For	a	flight	under	IFR	or	a	flight	not	in	the	vicinity	of	an	airport,	weather	reports	

and	forecast,	fuel	requirements,	alternatives	available	if	the	planned	flight	cannot	be	

completed,	and	any	known	traffic	delays	of	which	the	pilot	in	command	has	been	

advised	by	ATC;	actions	including	reviewing	weather,	flight	battery	requirements,	

landing	and	takeoff	distances,	and	aircraft	performance	data	before	starting	a	flight.

Jeff	Caprine,	DBA	321	Fish	On will	be	operating	my	sUAS	in	VFR	(visual	flight	rules).	

321	Fish	On	will	conduct	preflight	procedures	directly	pertaining	to	his	sUAS	

Manual,	which	includes	equipment	checklist	as	well	as	preplanning	details	

regarding	weather	conditions,	review	of	any	possible	flight	path	of	general	aviation,	

out	mission	flight	path	and	weather	conditions	amongst	other	parameters	required	

to	complete	the	mission.

14	C.F.R.	§91.109:	Flight	Instruction

Jeff	Caprine,	DBA	321	Fish	On seeks	exemption	from	14	C.F.R.	§91.109,	which	

discusses	flight	instruction,	simulated	instrument	flight,	and	certain	flight	tests.	

Specifically,	§91.109	states	“(a)	No	person	operate	a	civil	aircraft	(except	a	manned	

free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	fully	

functional	dual	controls.	

Jeff	Caprine,	DBA	321	Fish	On believes	that	there	is	inconclusive	evidence	that	a	

person	with	a	private	pilot	certificate	or	license	can	successfully	maneuver	or	train	a	

person	to	use	an	sUAS	without	first	hand	flight	experience	with	particular	sUAS.	

Flying	3rd person	orientation	requires	built-up	experience	in	that	form	of	flying.	

Also,	the	sUAS	will	be	operated	by	remote	control,	which	will	only	require	a	single	

person	operator	and	dual	controls	will	not	be	necessary.

14	C.F.R.	§91.119:	Minimum	Safe	Altitudes

Jeff	Caprine,	DBA	321	Fish	On seeks	exemption	from	14	C.F.R.	§91.119,	which	

discusses	minimum	safe	altitudes.	As	this	exemption	is	for	a	sUAS	that	is	helicopter	

and	the	exemption	requests	authority	to	operate	at	altitudes	up	to	400	feet	AGL,	or	

not	more	than	200	feet	above	an	elevated	platform	from	which	filming	is	planned,	

an	exemption	may	be	needed	to	allow	such	operations.	As	set	forth	herein,	except	

for	the	limited	conditions	stated	in	the	Manual,	the	sUAS	will	never	operate	higher	

that	400	feet	AGL.	It	will	however	be	operated	in	a	restricted	area	with	security	

perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	without	

their	pre-obtained	consent.
The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and	speed,	of	

the	UAS as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	

the	permission	of	the	property	owner	or	the	local	officials.	Because	of	the	advance	

notice	to	the	property	owner	and	participants	in	the	filming	activity,	all	affected	

individuals	will	be	aware	of	the	planned	flight	operations	as	set	forth	in	the	Manual.	

Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	for	more	that	the	

maximum	55lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk associated	

with	these	operations	is	far	less	than	those	presently	presented	with	conventional	

aircraft	operating	at	or	below	500	feet	AGL	in	the	movie	industry.	In	addition,	the	

low	–altitude	operations	of	the	sUAS	will	ensure	separation	between	these	smallUAS	operations	and the	operations	of	conventional	aircraft	that	must	comply	with	

Section	§91.199.

14	C.F.R.	§91.121	– Altimeter	Settings

Jeff	Caprine,	DBA	321	Fish	On seeks	exemption	from	14	C.F.R.	§91.121,	which	

discusses	altimeter	settings	for	lowest	usable	flight	level.	This	regulation	requires	

each	person	operating	an	aircraft	to	maintain	cruising	altitude	by	reference	to	an	

altimeter	that	is	set...”to	the	elevation	of	the	departure	airport	or	an	appropriate	

altimeter	setting	available	before	departure.”	As	the	sUAS	may not	have	a	

barometric	altimeter,	but	instead	a	GPS altitude	readout,	an	exemption	may	be	

needed.	An	equivalent	level	of	safety	will	be	achieved	by	the	Pilot/”Operator”,	

pursuant	to	the	safety	checklist	and	live	fight	data	monitoring,	confirming	the	

altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.

14	C.F.R.	§91.151	– Fuel	Requirements	for	flights	in	Visual	Flights	Rules	(VFR)	

Conditions

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14	C.F.R.	§91.151,	which	

discusses	fuel	requirements	for	flight	VFR	conditions.	Specifically,	19.151	states	“(a)	

No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	

(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	

first	point	of	intended landing	and,	assuming	normal	cruising	speed	– (1)	During	the	

day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	

least	45	minutes.	(b)	No	person	may	begin	a	flight	in	a	rotorcraft	under	VFR	

condition	unless	(considering	wind	and	forecast	weather	conditions)	there	is	

enough	fuel	to	fly	to	the	first	point	of	intended	landing	and,	assuming	normal	

cruising	speed,	to	fly	after	that	for	at	least	20	minutes.

321	Fish	On sUAS	operates	on	a	battery	that	provides	less	than	30	minutes	of	

powered	flight.	To	meet	the	30	minute	reserve	required	in	14	C.F.R.	§91.151,	sUAS	

flights	would	be	limited	to	approximately	15	minutes	in	length.	Given	the	limitations	

on	the	sUAS’s	proposed	flight	area	and	the	location	of	its	proposed	operations with	a	

predetermined	area,	a	longer	timeframe	for	flight	in	daylight	or	twilight	VFR	

conditions	is	reasonable.
321	Fish	On believes	am	equivalent	level	of	safety	will	be	achieved	by	limiting	flights	

to	15	minutes	or	20%	of	battery	power	– whichever	comes first.	This	restriction	

would	be	more	than	adequate	to	return	the	sUAS	to	its	planned	landing	zone	from	

anywhere	in	its	limited	operating	area.	Similar	exemptions	have	been	granted	to	

other	operations,	including	Exemptions	2689F,	5745,	10673,	and	10808.

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	

Registration

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	14	C.F.R.	§91,203	(a)	(b),	

which	states	(a)	No	person	may	operate	a	civil	aircraft	unless	it	has	within	it	the	

following:	(1)	An	appropriate	and	current	airworthiness	certificate....

(b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	

required	by	paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued	

under	§91.715 is	displayed	t	the	cabin	cockpit	or	cockpit	entrance	so	that	it	is	legible	

to	passengers	or	crew.

The	sUAS	fully	loaded	weighs	less	than	55	lbs.	and	is	operated	without	an	onboard	

pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification	and	registration	

documents	or	to	display	them	on	the	sUAS.

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	

ground	control	point	where	the	Pilot/”Operator”	flying	the	sUAS	will	have	

immediate	access	to	the	documents,	to	the	extent	they	are	applicable	to	the	sUAS.	

The	FAA	has	issued	numerous	exemptions	to	this	regulation.	A	representative	

sample	of	other	exception	includes	Exemptions	Nos.	9565,	9665,	9789,	9789A,	

9797,	9797A,	9816A,	and	10700.

14	C.F.R.	§91.405	(a),	§91.407	(a)	(1),	§91.409	(a), and	§91.717	(a)	&	(b):	

Maintenance	Inspections

Jeff	Caprine,	DBA	321	Fish	On,	seeks	exemption	from	the	14	C.F.R.	§91.405	(a),	

§91.407	(a)	(1),	§91.409	(a),	and	§91.717	(a)	&	(b),	which	discusses	required	

aircraft	maintenance,	operation	after	maintenance, preventive	maintenance,	

rebuilding,	or	alteration,	inspections,	and	maintenance	records.	321	Fish	On

believes	these	regulations	are	meant	for	manned	operated	aircrafts	with	an	

airworthiness	certificate	and	not	for	sUAS,	therefore	making	them	unnecessary.	

Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual	and	

operating	handbook.	An	equivalent	level	of	safety	will	be	achieved	because	the	sUAS	

is	very	limited	in	size	and	will	carry	a	small	payload	and	operate	only	in	limited	

areas	for	short	periods	of	time.	If	mechanical	issues	arise,	the	sUAS	can	land	

immediately	and	will	be	operating	from	no	higher	than	500	feet	AGL.	The	

Pilot/”Operator”	will	ensure	that	the	sUAS	is	in	working	order	prior	to	initiating	

flight,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance	performed.	
Moreover,	the	Pilot/”Operator”	is	the	person	most	familiar	with	the	aircraft	and	is	

best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	provide	the	

equivalent	level	of	safety.	An	equivalent	level	of	safety	will	be	achieved	because	

maintenance	and	inspections	will	be	performed	in	accordance	with	the	sUAS	

manufacturer’s	manual,	as	referenced	in	the	Aircraft	Operations	Manual.	As	

provided	in	the	Operations	Manual,	the	Pilot/”Operator”	will	ensure	that	the	sUAS	is	

in	working	order	prior	to	initiating	flight	and	perform	required	maintenance	

needed.

Summary

Pursuant	to	14	C.F.R.	part	11,	the	following	summary	is	provided	for	publication	in	

the	Federal	Register,	should	it	be	determined	that	publication	is	needed:	14	CFR	

Part	21,	14	CFR	§45.23	(b),	14	CFR	§61.113	(a)	&	(b),	14	CFR	§91.9	(b)	(2),	14	CFR	

§91.103	(b),	14	CFR	§91.109,	14	CFR	§91.119,	14	CFR	§91.121,	14	CFR	§91.151	(a),	

14	CFR	§91.203	(a)	&	(b),	14	CFR	§91.405	(a),	14	CFR	§91,407	(a)	(1),	14	CFR	

§91.409	(a)	(2),	14	CFR	§91.417	(a)	&	(b)	to	commercially	operate	a	small	

unmanned	vehicle	(55	lbs.	or	less)	equipped	to	conduct	aerial	videography	and	

photography	services.

Approval	of	exemptions	allowing	commercial	operations	of	sUAS	to	conduct	aerial	

videography	and	photography	services	will	enhance	safety	by	reducing	risk.	

Conventional	photography	operations,	using	jet	or	piston	powered	aircraft,	at	

extremely	low	altitudes,	often	very	close	to	the	subject	being	filmed	and	in	close	

proximity to	people	and	structures;	and	present	the	risks	associated	with	vehicles	

that	exceed	3,000	lbs.,	carrying	large	amounts	of	fuel.	In	contrast,	a	sUAS	weighing	

fewer	than	55	lbs.	and	powered	by	batteries	eliminate	virtually	all	of	that	risk	given	

the	reduced	mass	and	lack	of	combustible	fuel	carried	on	board.	The	sUAS	is	carried	

to	the	location.	The	sUAS	will	carry	no	passengers	or	crew	and,	therefore,	will	not	

expose	them	to	the	risks	associated	with	manned	aircraft	flights.

The	operation	of	small	sUASs,	weighing	less	than	55	lbs.,	conducted	in	the	

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	he	

granting	of	the	exemptions	requested	herein,	including	the	applicant	from	the	

requirements	of	Part	21	and	allowing	commercial	operations.	These	lightweight	

aircraft	operate	at	slow	speeds,	close	to	the	ground	but	under	500	feet	AGL,	and	

within	a	limited	are	and,	as	a	result,	are	far	safer	than	conventional	flight	operations	

conducted	with	turbine	helicopters	operating	in	close	proximity	to	the	ground	and	

people.

Privacy

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

representative	or	owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	
who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	

where	filming	will	take	place.

All	flight	will	occur	in	accordance	with	any	state	or	local	laws	regarding	privacy.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	od	2012—size,	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	area	and	

operation	within	visual	line	of	sight	and	national	security	– provided	more	than	

adequate	justification	for	the	granting	of	the	requested	exemptions	allowing	

commercial	operation	of	applicant’s	sUAS	in	the	aerial	videography	and	

photography	service	s	industry.

UASs	Specifications

Aircraft	make	– DJI	

Aircraft	Model	- INSPIRE	1	

Aircraft	Type	- Multi-Rotor	Rotorcraft	UASs	

Aircraft	Weight	(Battery	Included) 2935	g (6.47	lbs.)

Further	information	can	be	located	in	the	DJI	INSPIRE	aircraft manual(s).

http://www.dji.com/product/inspire-1/info#specs

Respectfully	submitted,

Jeff	Caprine

Vice	President

321	Fish	On