Orlando Production, Inc. 8761 Atwater Loop

Oviedo, Florida 32765 

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May 9, 2015 

U.S. Department of Transportation, Docket Operations 

Attn: Federal Aviation Administration (FAA) Administrator 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Administrator, 

Orlando Production Inc. (OPI) would like the Federal Aviation Administration (FAA) to consider this letter 

as its formal Section 333, Waiver and Exemption. As a leader in the digital photography and cinematic 

industries. OPI caters to a wide variety of photographic needs required to support of its clients, both 

private and commercial. 

OPI has assembled a uniquely qualified aerial imaging team with extensive qualifications to ensure 

quality and safe small Unmanned Aircraft System (sUAS) operations. The team’s qualifications include 

over 20 years of cinematic and photographic imaging and 15 years of experience in FAA Part 61, 65, and 

141 pilot training, maintenance, and commercial flight operations. 

Understanding the overwhelming demand for aerial photography and now more accessible with the 

advent of Unmanned Aerial Systems (UAS), OPI has positioned itself to provide and answer this need in 

a safe and professional manor. 

Orlando Production Inc. commends the Federal Aviation Administration’s (FAA) for its recent action in 

publishing the proposed sUAS rule. OPI understands that until the new rule becomes law that the FAA 

still needs to ensure the safety of the NAS (National Airspace System) for all users. This collective goal is 

the motivation for OPI to employ subject matter experts (SME’s) from both the aviation and 

photography industries. Furthermore, OPI’s aerial sUAS division will adopt industry accepted “best 

practices” as its processes and procedures to allow for safe and successful sUAS operations. 

At this time, OPI has invested in professional grade sUAS platforms, as well as, imaging and sensing 

devices in an effort to provide its clients with a variety aerial services. In doing so, OPI will only employ 

qualified Pilot/Observer operators who are familiar with Federal Aviation Regulations (FAR) and the 

guidance and/or restrictions provided for in the approval of this exemption. 

Furthermore, DroneLife.com sited a Bloomberg report stating that Amazon has sold more than 10,000 

devices per month in 2014. With over 1 million UAS platforms in operation today, OPI is looking to 

provide the safety of proven aviation operational standards to meet the demand for private and 

commercial imaging while ensuring UAS operations are also conducted within the legal guidelines that 

this exemption will provide. 
Orlando Production, Inc. 8761 Atwater Loop

Oviedo, Florida 32765 

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It is the sincere hope of Orlando Production, Inc. and its staff, that the Administrator grant this 

exemption as it believes it has met the congressional mandate to “operate safely in the National 

Airspace System.” 

Please find attached OPI’s regulatory compliance of title 14 CFR §11.81 regarding the petition for an 

exemption allowed for under Public Law 112-95 §333. 

Respectfully, 

Nicholas Schultz 

Orlando Production, Inc. 

Director of Aerial Operations 

8761 Atwater Loop 

Oviedo, FL 32765 

C: 321-438-2672 

Nick@OrlandoProduction.com 

exemption allowed for under 

Respectfully,

Nicholas Schultz

Orlando Production Inc
Orlando Production, Inc. 8761 Atwater Loop

Oviedo, Florida 32765 

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Information Supporting Orlando Production, Inc., Petition for Exception, 

Public Law 112-95 §333 - Special Rules for Certain Unmanned Aircraft 

Systems, as Specified in 14 C.F.R. §11.81 

A. Mailing address and other contact information: 

Orlando Production, Inc. 

Attn: Nicholas Schultz 

8761 Atwater Loop 

Oviedo, FL 32765 

C: 321-438-2672 

Nick@OrlandoProduction.com

Orlando Production, Inc. 

Attn: William Shanley 

8761 Atwater Loop 

Oviedo, FL 32765 

C: 407-765-8210 

Bill@OrlandoProduction.com 

B. The specific section or sections of 14 C.F.R from which Orlando Production, Inc. (OPI) seeks 

exemption: 

OPI seeks exemption from applicable title 14 Code of Federal Regulations (CFRs) relevant to small 

Unmanned Aircraft System (sUAS), as defined by the FAA, operations. The below list, includes but is not 

limited to, regulations limiting sUAS operations. 

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

3. 49 USC § 44711 Prohibitions and exemption 

4. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 

5. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

6. 14 CFR 91.119 Minimum Safe Altitudes. 

7. 14 CFR 91.121 Altimeter Settings. 

8. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 

9. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations. 

10. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer Medical. 

C. The extent of relief, and the reason for relief: 

Orlando Production, Inc. is requesting relief from multiple regulatory constraints under title 14 CFR Parts 

21, 45, 61, 65, 91 as well as other UAS regulatory guidance under FAA Notice 8900.227, Public Law 112-

95, Title 49 United States Code (USC), with regards to Unmanned Aircraft System (UAS) operations, 

more specifically sUAS commercial operations. 

OPI would like, with the permission of the Administrator, to provide sUAS aerial imaging and sensing 

with the intended use to include but not limit the following: 

x Aerial services including 
Orlando Production, Inc. 8761 Atwater Loop

Oviedo, Florida 32765 

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o Photography 

o Cinematography 

o Survey 

Detailed below is a list of operational safeguards OPI believes are essential for safe operations of which 

many have been previously approved by the Administer for similar sUAS operations. In addition, OPI 

will not commence sUAS operation that will create an undue hazard to users of the national airspace 

system (NAS), the public, or pose a threat to national security. 

OPI has published and/or adopted the following documents to be an integral part of its sUAS operations. 

x OPI Flight Operations Manual (Flight Ops Manual) 

x Motion Picture and Television Operations Manual (MPTOM) 

x DJI Published 

x User Manuals 

x Maintenance Manuals 

x Propeller Locks Manuals 

x Safety Guidelines 

x Flight Battery Safety Guidelines 

x Release Notes 

x Lightbridge (optional) 

x Lightbridge User Manual 

x OPI Published 

x Pilot’s Operating Manual (POH)/Aircraft Flight Manual (AFM) 

x Spreading Wings S1000+ 

x Mission Planner/Firmware 

x User Manuals 

x Planning Manuals 

Furthermore, OPI will ensure all operations are in compliance with these documents and/or other more 

recent and relevant documents that OPI determines will improve the safety and crew resource 

management (CRM) of the OPI aerial team. 

OPI believes the this request is consistent with the congressional mandate in Section 333 of the FAA 

modernization and Reform Act of 2012 and will allow OPI to operate sUAS in a legal, safe, and publicly 

beneficial way which exceed the standards currently permitted for recreational use. 

D. The reasons why granting Orlando Production, Inc.’s request would be in the public interest; that 

is, how it would benefit the public as a whole: 

By the granting of this exemption the public will benefit from the worldwide well-publicized benefits of 

UAS operations which include: 

x Public safety 
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Oviedo, Florida 32765 

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x United States infrastructure 

o Bridges inspection 

o Building inspection 

o Utility inspection 

 Power 

 Communication 

x Unimproved Property Imaging 

o Agricultural 

 Surveying 

 Crop Inspection 

x Improved Property Imaging 

o Commercial and Residential 

o Structural inspection 

o Exterior appliance inspection 

x Economic Development Benefits 

x Marketing 

The benefits of sUAS operations is exhaustive and the uses of these devised will allow public, private, 

and personal entities to benefit from the expertise OPI has to offer while mitigating the physical safety 

hazards of the current legally approved imaging methods as well as the cost reduction made possible by 

sUAS platforms. 

OPI is confident that the granting of this exemption will allow OPI to continue providing a high quality 

solutions for its client base while minimizing the risk of accidents and/or damage to persons or property. 

The positive impacts will be felt by the families of our employees, the improved safety of our neighbors, 

and our community as a whole. 

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which Orlando 

Production, Inc. seeks the exemption: 

As documented above, OPI’s sUAS operational procedures will provide a level of safety that far exceeds 

the level of safety currently required by the FAA for hobbyist and manufacturers of model aircraft. The 

following operating procedures will apply during all sUAS operations under this exemption. 

1. The below chosen sUAS(s) will not exceed the operational weight or maximum gross takeoff 

weight (MGTOW) as defined by the FAA and currently limited to a MGTOW of 55 pounds. 

i. DJI 

a. Phantom Series 

b. Inspire Series 

c. Spreading Wings S1000+ 

a. Optional 

x DJI Lightbridge (Advanced Datalink System) 
Orlando Production, Inc. 8761 Atwater Loop

Oviedo, Florida 32765 

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2. Approved airframes will not exceed an airspeed of 87 knots (100 miles per hour) or “maximum 

never-exceed speed (VNE)” published and/or recommended by the airframe manufacturer, 

whichever is lower. 

3. sUAS operations will not exceed the reported absolute altitude of 400 feet or 50 feet above and 

50 feet laterally from the highest point of the target structure. 

4. All sUAS Pilot in Command (PIC) will operate with visual line of sight (VLOS) at all times where 

the VLOS will be human unaided vision by any devise other than corrective lenses as specified 

on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

5. Operations requiring the use of Visual Observers (VO) 

i. All sUAS operations not employing geo-fencing technology, where geo-fencing 

technology is a technology that utilizes the onboard GPS with software to create a 

virtual boundary around the target structure 

ii. All operations operating more than 50 feet laterally of a target structure and/or a 

reported absolute altitude over 200 feet 

iii. All operation where individuals not associated with the operation are within the vicinity 

6. Visual Observer requirements 

i. The sUAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all 

times. The VO may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate verbally at all 

times; electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties required 

of the VO. 

7. The PIC must have all available information required to ensure successful flight. This 

information must be accessible during sUAS operations. 

i. All available information must include the following, at a minimum: 

a. All documents needed to operate the sUAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. 

b. If a discrepancy exists between the conditions and limitations in this exemption 

and the procedures outlined in the operating documents, the conditions and 

limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. 

c. It is the operator’s responsibility to track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official 

upon request. 

d. The operator must also present updated and revised documents if it petitions 

for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for an amendment 
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Oviedo, Florida 32765 

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to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating 

documents. 

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

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

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

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g. inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

13. The PIC must hold a certificate issued under 14 CFR Part 61. 

The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, 

or the Federal government. 

14. OPI will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. 

i. OPI will only utilize a PIC who has completed standardized training and has a minimum 

of 25 hours of documented flight experience in sUAS operations and at least 5 hours on 

each device type and category prior to any exempted commercial operation. 

ii. PIC qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the sUAS in a manner consistent with how the sUAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 
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Oviedo, Florida 32765 

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15. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). 

16. The unmanned aerial vehicle UAV may not operate at or above a reported absolute altitude of 

500 feet within 3 nautical miles of an airport reference point (ARP) as denoted in the current 

FAA Airport/Facility Directory (A/FD) or for airports without a published aeronautical chart, 

unless a letter of agreement with that airport’s management is obtained or otherwise permitted 

by a COA issued to the exemption holder. The letter of agreement with the airport 

management will be made available to the Administrator or any law enforcement official upon 

request. 

i. The UAV may operate above a reported absolute altitude of 500 feet providing OPI has 

gained prior written approval from the air traffic authority responsible for the restricted 

airspace. 

17. The UAV may not be operated less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAV loses communications or loses its GPS signal, the UAV must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UAV to conduct the intended operation and 

to operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. All aircraft operated in accordance with this exemption must 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 must be as large as practicable. 

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

23. The UAV must remain clear and give way to all manned aviation operations and activities at all 

times. 

24. The UAS may not be operated by the PIC from any moving device or vehicle. 

25. All flight operations must be conducted at least 200 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

i. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAV and/or debris in the event of an accident. The operator must ensure where 

nonparticipating persons leave such protection and are within 200 feet of the UAV, 

flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons; and 

ii. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk 
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Oviedo, Florida 32765 

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of operating closer to those objects and determined that it does not present an undue 

hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons 

under this exemption. 

26. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

28. Closed-set motion picture and television filming and production OPI will observe and abide by all 

procedures as is contained in a motion picture and television operations manual (MPTOM). 

29. For flight operations closer than 200 feet from participating persons consenting to be involved 

and necessary for the filming production will be conducted in accordance with and as specified 

in OPI’s MPTOM. 

F. Additional information and view: 

Orlando Production, Inc. would ask that the Administrator consider all previously awarded exemptions 

as supporting arguments to this exemption request. 

Additionally, due to file size limitations of the FAA electronic comment/request system, OPI will provide, 

upon request, detailed specifications, operational procedures, and optional equipment documentation. 

OPI would like to thank the FAA for its consideration as our team awaits a positive outcome to this 

request. 

Should the Administrator require any additional information or clarification please do not hesitate to 

contact myself or Mr. William Shanley directly. 

Respectfully, 

Nicholas Schultz 

Orlando Production, Inc. 

Director of Aerial Operations 

8761 Atwater Loop 

Oviedo, FL 32765 

C: 321-438-2672 

Nick@OrlandoProduction.com 

Respectfully,

Nicholas Schultz

Orlando Production Inc