July 27, 2015

Kenji Croman

Tie The Knot Images, LLC

Owner: Kenji Croman 

2555 Pacific Heights Place

Honolulu, HI 96813

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) 

and (b)

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR 

Part 11, Kenji Croman, operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would 

operate in the following manner: 

 Aerial photography and/or video for public and/or private use including real estate, architecture, land

surveying, engineering and other related professional activities. 

 Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and newsgathering.

 Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority. 

 Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers. 
 Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has 

requested it by contract or donation. 

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the 

protection of the persons and property. 

As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety

enhancements to the already safe operations in the industry presently using conventional aircraft. 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 systems in 

the national airspace system.” 

The name and address of the applicant is:

Tie The Knot Images, LLC

Attn: Kenji Croman , Owner/Chief Pilot Email: kenjic@mac.com

Address: 2555 Pacific Heights Place, Honolulu HI 96813

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

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 

14 CFR 91.109 

14 CFR 91.119 (c) s
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) 

We are petitioning for exemption to enable Tie The Knot Images, LLC to operate a DJI Inspire 1 equipped with

a three-axis gimbals and using High-Def cameras. This sUAV has a built-in capability to limit the height it flies 

above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class 8, C 

and D airspace including a no-fly zone feature. The Inspire 1 also has the fail-safe function of the Naza-M 

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. The DJI Inspire 1 

has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 

11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UAs are equipped with four

main rotors; driven by Lithium Polymer battery powered electric motors. 

Given the small size of the UAS and the controlled environment provided the proposed operations would adhere 

to the Reform Act’s safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

 The	UAS	will	weigh	less	than	55	lbs.

 The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	40mph.

 Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual			

Observer	(VO).		
 Maximum	flight	time	for	each	operational	flight	will	be	20	minutes.	Flights	will	be	terminated	

at	25% battery	power	reserve	or	20	minutes	of	flight	time	whichever	occurs	first.		

 Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(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,	the	Visual	Observer	(VO)	and	

may	include	but	not	limited	to	a	Camera	Operator.		

 The	UAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	will	take	and	pass	all	necessary

certifications	currently	being	approved	by	the	FAA	administration	for	commercial	use.		

 A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight	

consisting	of	all	the	days’	production	activities.		

 All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions	(VMC)	only.		

 The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	center/Airport	Reference	

Point (ARP)	of	a	tower	controlled	or	uncontrolled	airport.	

 The	DJI Inspire	1 has	built	in	software	for	all	FAA	regulated	‘No	Fly	Zones’	and	was	uploaded	

by	DJI	(February	2015)	for	all	DJI	drones	to	download	and	prevent	any	possible	flights	

occurring	within	no-fly	zones.	DJI	Inspire	1 has	installed	software	(code)	that	denies	flights	

within	the	FAA	no-fly	zones.		If	operations	will	be	within	a	5	mile	radius	of	the	geographic	

center/Airport	Reference	Point	(ARP)	of	a	tower	controlled	or	uncontrolled	airport	the	

respective	airports	will	be	contacted	advising	them	of	the	estimated	flight	time,	flight	duration,	

elevation	of	flight	and	other	pertinent	information.		

 The	operator	will	file	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	of	the	requested	

exemption,	with	the	appropriate	local	Flight	Standards	District	Office	(FSDO)	no	more	than	72	

hours	but	no	less	than	48	hours	from	planned	operation.		

 The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned	

operation	and	ensure	that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	flight	

operation,	and	the	radius	may	be	reduced	to	30	feet	based	upon	an	equivalent level	of	safety	

determination,	as	required	under	the	FOM.	With	the	advanced	permission	of	the	FSDO,	

operations	at	closer	range	may	be	approved.		

 The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up-to-date	information	

for	the	particular	UAS	to	be	operated.		

 The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times.		
 Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county	

or	city	jurisdictions,	including	law	enforcement,	fire	or	other	appropriate	governmental	

agencies.		

 If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will	

have	the	capability	to	return	to	a	pre-determined	location	within	a	designated	location	and	

land	autonomously.		

 The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or	

emergencies.	

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

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

controlled and monitored by both the operator and under the requirements and in compliance with local 

public safety requirements. The FAA will have advance notice of all operations. These safety enhancements 

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 credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability

to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 
The regulation requires: 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

certificated aircraft, the operator must also display on that aircraft near each 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. 

Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will 

have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed 

on the fuselage in compliance with §45.29 (f). 

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) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent level 

of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or 

passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will 

equate to the safe operation of the UAS. 

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no 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 check lists 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. 

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. The UAS, given its 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 flying the UAS will have immediate 

access to it. 
14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely

piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number of aircraft and for 

flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a 

pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters 

to be operated at less than the minimums prescribed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which filming is planned, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. 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, 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 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. Compared to flight operations with aircraft or rotorcraft weighting far more than 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 AGL. In addition, the 

low-altitude operations of the UAS will ensure separation between these UAS operations and the operations 

of conventional aircraft that must comply with Section 91.119. 
14 C.F.R. §91.121 Altimeter Settings. 

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 UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 

(a) Prohibits an individual from beginning “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.” The battery powering the UAS provides approximately 18 minutes 

of powered flight. To meet the 30 minute reserve requirement in 

14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations 

on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a 

longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an 

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a 

tightly controlled area where only people and property owners or official representatives who have signed 

waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting 

UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% 

of battery power— whichever happens first. This restriction would be more than adequate to return the UAS 

to its planned landing zone from anywhere in its limited operating area. 

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

The regulation provides in pertinent part: (a) Except as provided in § 91.715, 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 at the cabin or cockpit entrance so 

that it is legible to passengers or crew. The UAS fully loaded weighs no more 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 UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UAS will have immediate access to them; to 

the extent they are applicable to the UAS. 
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed 

in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to the applicant. 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 UAS is very limited in size and will carry a small payload and operate 

only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately

and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and 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 UAS 

Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working 

order prior to initiating flight and perform required maintenance needed. 

Public Interest

Manned aircraft conducting aerial photography/videography can weigh 6,000 pounds or more and contain one 

or more individuals on board. Tie The Knot Images, LLC’s UAV will weigh less than 7 pounds and contain no 

living crew (the PIC and VO being remotely located from the UAV). The limited weight significantly reduces 

the potential for harm to participating and nonparticipating individuals or property in the event of an incident or 

accident. There is no risk to an onboard crew while using a UAV.

Traditional manned aircraft contain highly flammable fuel and are at risk of fuel spillage and fire in the event of 

an incident or accident. The battery-powered Inspire 1 carries no fuel, eliminating this fire and environmental 

risk.

Traditional aerial photography/videography operations using conventional aircraft can operate in very close 

proximity to persons and property on the ground. While the FAA mitigates these risks in a variety of ways, the 

proposed UAS operations would reduce risks even further due to the limited size, weight, speed, operating 

conditions, and safety features of the Inspire 1.

Furthermore, as Congress outlined in the FAA Modernization and Reform Act, integration of UAS into the 

NAS is inherently in the public interest, as long as it can be accomplished safely.

As described above, not only will the proposed UAS operations provide an equivalent level of safety to current 

operations – they will actually provide a greatly improved level of safety to construction managers and the 

general public.
Conclusion

Tie The Knot Images, LLC seeks exemption from the FARS outlined above in order to commercially operate a 

small UAV that weighs less than seven pounds for the purposes described above.

The operation of the UAS described herein, under the strict conditions outlined above and in the operating 

documents, will provide an equivalent level of safety to support the grant of the requested exemptions.

Please do not hesitate to contact me if you have any questions or concerns.

Sincerely,

Kenji Croman

Owner, Tie The Knot Images, LLC