December 23, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590-0001

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

Aviation Regulations from 14 C.F.R. Part 21 Subpart H; 14 C.F.R §§ 61.23(a) and (c);

61.101(e)(4) and (5); 61.113(a) and (b); 61.133(a); 91.7(a);

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.417(a) and (b) and any other 

applicable regulation affecting small Unmanned Aircraft Systems usage in the NAS.

Dear Mr. John S. Duncan:

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

Act”) and 14 C.F.R. Part 11, Christopher A. Bish Films (hereinafter “the petitioner/owner/operator”), 

an owner/operator of a small Unmanned Aircraft System (“sUAS”) equipped to conduct aerial 

photography and videography for weddings, real estate and other events, hereby applies for a

Section 333 exemption from the listed Federal Aviation Regulations (“FARs”) to allow the private and 

commercial operation of its sUAS, so long as such operations are conducted in strict compliance 

with and under the specific conditions established by the FAA.

The requested exemption would permit the safe and legal operation of a small sUAS

under very controlled conditions and would be limited in usage at pre-approved venues which

would provide safety enhancements in the airspace in which it will operate. Consequently, the 

approval of this exemption would be in the best interest of public safety and therefore, fulfill the

Secretary of Transportation’s responsibilities to “establish requirements for the safe operation of

such aircraft systems in the national airspace system.” under Section 333(c) of the Reform Act.

PETITIONER/OWNER/OPERATOR

Christopher A. Bish Films

1091 Wrayswood Circle

Greensboro, Georgia 30642

706.347.4094

Gbi103@gmail.com

Small Unmanned Aircraft System Owned/Operated by Petitioner:

DJI Phantom 3 ProfessionalModel – FAA Aircraft Registration Applied For

Weight: 1280G

Diagonal Size: 590mm

Ascent speed: 5 m/s

Descent speed: 3 m/s

Maximum speed: 16 m/s

Maximum flight time: 23+/- minutes

Controller: 2.4Ghz-2.483Ghz and is FCC compliant

jjjjjand any
Known Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart H

14 C.F.R. § 61.23(a) and (c)

14 C.F.R. § 61.101(e) 4 and 5

14 C.F.R. § 61.113(a) and (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.417(a) and (b)

Any other regulation governing/affecting sUAS usage in 

the NAS.

The Petitioner/Owner/Operator

Christopher A. Bish Films is a sole proprietor, professional photography and 

videography business that services private and commercial clients in the State of Georgia. The 

petitioner/owner/operator is committed to the public’s safety and is a licensed private pilot with a 

current medical certificate who will operate the sUAS in a safe and legal manner during all sUAS 

flight operations. The petitioner/owner/operator will comply with all applicable FAR’s and

requirements set forth by “the administrator” governing sUASs, should an exemption be granted.

Expertise and Experience

The sole proprietor has been engaged in professional photography and videography 

service in excess of five years and recently purchased a DJI aircraft to expand 

capabilities/services to offer the best possible imaging services to its clients. The

petitioner/owner/operator is also a certified law enforcement officer with a Masters Degree in Public 

Administration. The level of safety in which the afore identified sUAS will be operated pursuant to an 

authorized exemption will be of the utmost to guarantee the highest level of safety during the 

operation of the sUAS within the NAS.

Statutory Authority – Section 333

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a 

mechanism for seeking expedited FAA authorization of safe civil sUAS operations in the NAS. 

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the [comprehensive] plan and 

rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this 

Act.” In section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for 

“expedited operational authorization.” The FAA has committed to complying with this mandate by 

granting other petitions almost identical to this petition/application for exemption. (See numerous 

exemptions listed on the Regulatory Docket at www.regulations.gov granting regulatory 

exemptions to other aerial imaging businesses operating unmanned aircraft systems).

Sections 333(b) identifies several factors that the FAA should consider in determining 

whether commercial sUAS operations should be approved. These include sUAS that, “as a 

result of their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to the users of the [NAS] 

or the public or pose a threat to national security.” See Sections 333(b).
In addition to the specific authority conferred by section 333, the FAA

Administrator has general authority to grant exemptions from the FAA’s safety

regulations and minimum standards when the Administrator decides a requested

exemption is in the public interest. See U.S.C. § 44701(f).

Requested Exemptions

The petitioner seeks exemptions from the following regulations to safely and legally provide aerial imaging 

services to private and commercial clients in the State of Georgia.:

Summary

The petitioner, a 43 year veteran law enforcement official who is also a licensed private 

pilot, religiously abides by all rules, regulations, policies, procedures, laws and statutes as a United 

States citizen and wholeheartedly supports aviation safety, especially since the introduction of 

sUAS operated aircraft in the NAS. The petitioner believes his background, education, 

professional training and experience guarantees strict adherence with the specific guidelines and 

procedures proposed by the FAA governing sUAS usage and that this petition is in the best interest 

of the public’s safety. Moreover, the FAA has already recognized sUAS usage in the filmmaking 

industry, issued exemptions in identical circumstances, and should therefore consider issuing the 

requested exemption. 

The petitioner/owner/operator will follow the manufacturers recommended pre-flight safety 

procedures to ensure the aircraft is airworthy prior to each flight. Furthermore, the 

petitioner/owner/operator will follow all VFR rules and will always maintain visual contact with the 

aircraft, which will never exceed 250’ AGL. Moreover, the petitioner/owner/operator will obtain 

permission from the respective property owners before deploying the sUAS so as not to intrude 

upon the privacy rights of others and will always maintain safe altitudes/distances from structures 

and individuals present while conducting aerial operations.

Therefore, the petitioner/owner/operator respectfully requests consideration for the afore 

identified exemptions to facilitate the safe and legal use of the sUAS for the private and

commercial imaging services within the State of Georgia.

Respectfully submitted,

Christopher A. Bish, MPA

14 C.F.R. Part 21 Subpart H

14 C.F.R. § 61.23(a) and (c)

14 C.F.R. § 61.101(e) 4 and 5

14 C.F.R. § 61.113(a) and (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.417(a) and (b)

Any other regulation governing/affecting sUAS usage in 

the NAS.