Wild Bill Productions 

Bill Reynolds Owner Sole Proprietor 

206 Millpond Road 

Sunbury, Ohio 43074 

legalmedia@ hot:mail.com 

U.S. Department of Transportation 

Docket Management Facility 

1200 New Jersey AvenueJ SE 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

Dear Exemption Manager, 

Section 333 Exemption Petition 

Wild Bill Productions (WBP} is submitting a Petition for Exemption for Small Unmanned Aircraft Systems 

operations. I am an experienced Hobby PIC (Pilot in Command) of UAS (Unmanned Aircraft Systems) 

with over 500 flight hours. I take the skills and education for safe operation very seriously. My 

companies name is no indication of my attitude towards UAS operation, it is directly related to my video 

editing style. 

This WBP request is for a waiver of the sections identified below in an effort to operate a UAS for 

commercial applications: I.E. crop field management, Real Estate Marketing Purposes, and live sporting 

events. Although UAS video and photography makes up a small part of my video productions, it is 

imperative that all steps be taken to comply with current regulations and safety protocols. 

It is my goal, as a UAS operator, to make every responsible effort to avoid invading a person's 

reasonable expectation of privacy when operating the UAS while performing safe flight operations. 

When operating the UAS, I will abide by all FAA Regulations for flight and receive the proper 

authorization for flight. This includes my VO (Visual Observer) as well. All flights are VLS (Visual Line of 

Sight) only and the duration of flights are limited to 15 minutes monitored by automated digital alarm 

and manual timer. AU flight wHt be under 300 feet. 

WBP is a small local business supporting and promoting the safe and responsible implementation of UAS 

into our national airspace (NAS). WBP will offer its local market an accredited UAS option to aid in aerial 

imagery gathering. WBP uses a small unmanned unit (OJ I Phantom 2) that has the capacity to perform 

work that would requir~ and m some cases not be possible to perform with a full scaJe fixed winged 

aircraft and pilot, thus reducing risk to people and property. Also, WBP makes aerial video and 

photography affordable to individuals and business that are not able to afford fixed wing productions. 

Thjs request specificaUy s.entP" the pubJic and economic interest to aide jn the areas stated above. The 

granting of this exemption would make logical sense because of my professional approach to UAS 

operations, my clear understanding of FAA rules, my awareness of operational and restricted airspace, 

my experience as a UAS Pilot, and my attitude of safety first when it comes to flight operations. 
7 

Suggested Public Federal Register Summary: 

"The petitioner is seeking an exemption to operate unmanned aircraft systems (UAS) with a maximum 

weight of Jess than six pounds to perform Professional Marketing Services: Produce Management, Real 

Estate and Live Sporting Events. Data gathered may include still and moving images captured with 

on board cameras." 

General Information Pertaining to AU Proposed UAS (Unmanned Airaaft Systems) 

WBP will operate a UAS of less than fifty-five pounds to conduct aerial imagery and videography, with 

payloads capable of supporting these missions. 

Prior to each flight the PiC shall inspect the UAS to ensure it is in a condition for safe flight. if the 

lnspemoo reveals a -.coo.diti.on that affects the safe operation nf the U.AS, the air-craft wDI be probiliited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. Ground Control Station will be included in preflight inspections as well. 

Maintenance and Alterations must be properly documented in aircraft records. 

Any maintenance or alterations made to the UAS shalt he .documente-d ln a logbook and the UAS must 

undergo and pass a test flight before it can return to service. Any repairs or alterations must meet the 

manufacturer's guidelines with particular attention to flight critical components that may not be 

addressed in the manufacturer's manuals. Only personnel who are authorized shall perform such 

operations. 

WB'Pwntfotfow afl manufacturer's UAS aircraft/component, maintenance, overhaut, rep1acement, 

inspection and life limit requirements, WBP shall carry out their maintenance, inspections and record 

keeping requirements, in accordance with the operator's manual. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight hours, description of work each 

UAS operated under the proposed exemption shall comply with all manufacturer System and Safety 

BulletJns. 

Equipment List: 

DJI Phantom 2 

WSP .seeks an exemption to -operate OJI Phantom 2. {UAS}t for compensation or hire. The Dlt Phantom 2 

is comprised of a quad-rotor unmanned aircraft and a handheld ground control station. The Phantom II 

has a maximum gross weight of approximately 2.8 pounds, diameter (rotor span) 23.75 inches, width of 

12.5 inches, and height of 8.1 inches. The Phantom II is equipped with four rotors driven by four lithium 

polymer battery powered electric motors. Design and operational characteristics are provided in DJI 

Phantom 2 Operating Manual (Page 35). Flight crews shalt conduct pre-flight inspmions as documented 

in OJ1 Phantom 2 Operating Manuat (Page 24) 

ATIACHMENTS 

DJI Zemuse H3 -3d Gimbal, DJIISOD mini, DJI2.4ghz. Data link, 14sg Futaba radio transmitter, Gopro 

Hero 3, OJt flight controtier. 
Flight Operations: 

I am wen aware of conducting safe fright operations and planning flight paths that eliminate any 

overflight of crowds. Any flight operations in town environments would typically be for dose air support 

for focused shots such as pre competition team warm-up at sporting events, crop produce observation, 

undeveloped property inspections, and/or golf course and real estate marketing. These operations 

occur in a very limited area and I would not need to overfly densely populated areas in general. 

Operations would be more vertical in nature offset/above shots of any specific event. 

My proposed public safety UAS operations are typically conducted at low altitudes less than 300 Feet 

AGL (within Class G airspace), not over crowds, and not near airports. Flights will end when battery 

reserve reaches 25 percent or timer sound alarm. In addition, preflight and post-flight checklists and 

UAS examinations will help detect any abnormalities prior to flight and after flight. If the WSP UAS is 

unable to .satisfy safety dlecknsts it will be removed fr-om service untU the issue can be resolved. 

Granting this request would not adversely affect safety since operations would be in accordance with 

current UAS rules. 

Section 333 Compliance and Appropriateness: 

Rased on t.':ie size of the .craft, experience of the pilot, and operational goats~ this req~Jest a~rs t.o he 

well suited for approval using the criteria outlined in Section 333 of the FAA Modernization and Reform 

Act of 2012 and will move safe flight operations forward in accordance with the intent of Section 333. 

WBP are currently seeking exemption of: 

Section of 14 CFR: parts 21 Subpart H, 27, 45.23{b), 45.27{a}. 61.113{a} and {b}, 61.133{a}, 91.7{a), 

91.9(b)(2), 91.103, 91.109{a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.319(a) (1), 91.405(a), 

91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) 

If WBP has erroneously omitted any other relevant section for our intended operations, please feel 

Free to suggest the missing section(s). All current User Manual and Operational Updates to software for 

the DJl Phantom can be found at the foUow!ng Hnk. WBP monitors this s!te to maintain a!! firmware and 

software updates. http://www.dji.com/product/phantom-2/download 

Conclusion: 

WBP believes it can perform safe, efficient and responsible flight operations whUe providing sen~ices to 

1oea1 businesses in a safe and affordabte manner. 

ey, 

Wilfiam T. Reynolds 

Owner Operator 

Wild BiU Productions 

740-803-2998 

legaimedia@hotmaiLcom