513 James Ridge Lane

Stockbridge, Ga. 30281

November 24, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Petition of Focus-On-Video, LLC for Exemption from Certain 

Federal Aviation Regulations to Operate Unmanned Aircraft Systems 

Pursuant to Section 333 of the FAA Modernization and Reform Act

Dear Sir or Madam:

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14

C.F.R. part 11, Focus-On-Video, LLC hereby petitions the Federal Aviation Administration

("FAA") for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a),

61.315(a), 91.7(a), 91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and

(2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Focus-On-Video, 

LLC to operate unmanned aircraft systems ("UAS") for aerial photography and video. Specifically, 

Focus-On-Video, LLC seeks to operate UAS for Aerial Photography, Videography and other 

commercial production, using the DJI Phantom 3. Because this petition is similar in all material 

respects to previously-granted Section 333 petitions, Focus-On-Video, LLC requests expedited 

approval pursuant to the FAA's summary grant process.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS

Focus-On-Video, LLC, a solely own corporation located in Stockbridge, GA. 

Focus-On-Video, LLC provides wedding and event photography and videography services.

Focus-On-Video, LLC was formed in 2003 by Bernard McRae, 513 James Ridge Lane, Stockbridge, 

Ga.

Focus-On-Video, LLC strives to provide wedding and event photography and videography services 

to the Atlanta and surrounding areas to the specific communities served. 

II. THE UAS

Focus-On-Video, LLC requests an exemption to operate the DJI Phantom 3 well below 55 pounds 

including payload. Through the Section 333 exemption process, the FAA has authorized use of all 

UAS for which exemption is requested herein.

III. REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has

granted, Focus-On-Video, LLC requests that the FAA issue a summary grant of exemption pursuant 

to the agency's expedited summary grant process. Specifically, the public interest and safety benefits.
IV. APPLICANT INFORMATION

The name and contact information of the applicant is:

Bernard McRae

President/ Owner

Focus-On-Video, LLC

513 James Ridge Lane

Stockbridge, Ga 30281

Phone: 770-957-4299

Regulations from which exemption is requested:

See Exemption No. 11274A to United Services Automobile Association, Regulatory Docket No. FAA2014-0796 (authorizing use of the DJI Phantom 3

V. OPERATING PARAMETERS

Focus-On-Video, LLC will adhere to the following operating parameters when operating UAS 

pursuant

to a grant of the requested exemption:

1. Operations will be conducted using the DJI Phantom 3

2. The UAS will not be operated at a speed exceeding 25 knots, at an altitude greater than 400

feet above ground level, or, when visibility is less than 1 statute miles, less than 500 feet 

below or 2,000 feet horizontally from a cloud. All operations will be conducted during the 

day under visual meteorological conditions.

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization 

("COA)

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the

UAS will remain within the visual line of sight of the PIC or the VO at all times. The PIC 

will maintain VLOS capability and the ability to communicate verbally with the VO at all 

times.

5. Focus-On-Video, LLC will ensure prior to operation that the PIC has demonstrated the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency will be logged in a manner consistent with 14 C.F.R. § 61.51(b).

6. Focus-On-Video, LLC operating documents will be accessible during UAS operations and 

made available to the Administrator upon request.

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

a condition for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has been 

performed and the U AS is found to be in a condition for safe flight.

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

flight characteristics, e.g., replacement of a flight critical component, will undergo a

functional test flight prior to conducting further operations under this exemption.

9. Focus-On-Video, LLC will follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements, as well as safety bulletins, for the 

aircraft and aircraft components.

10. Focus-On-Video, LLC will register and mark its UAS in accordance with 14 C.P.R. parts 47 

and 45.

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION
The FAA has authority to grant the exemption requested herein under the FMRA and the

Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the

national airspace, and directs the Secretary of Transportation to determine which UAS, "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 users of the national

airspace system or the public or pose a threat to national security."3 Section 333 further directs

the Secretary to "establish requirements for the safe operation of such aircraft systems in the

national airspace system. "4 The Federal Aviation Act authorizes the Administrator of the FAA

to grant exemptions from regulations prescribed under certain provisions of the Act where such

exemptions are in the public interest.5 Part 11 of the Federal Aviation Regulations governs the

FAA's exemption process and requirements.6 The FAA has granted more than 1,100 exemptions

to date pursuant to its Section 333 and exemption authority, enabling commercial UAS

operations in a wide variety of industries.

VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Should the FAA determine that publication in the Federal Register is required, Focus-On-Video, 

LLC offers the following summary pursuant to section 11.81 of the FAA's rules:7

Petitioner: Focus-On-Video, LLC

Sections of 14 C. FR. Affected: 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); 14 C.F.R. § 61.315(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. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14

C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks relief from the requirements of 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); 14 C.F.R. §

61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. §

91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and

(2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for newsgathering,

content production, and facilities inspection.

VIII. CONCLUSION

As demonstrated above, the UAS operations Focus-On-Video, LLC has proposed in this petition for

exemption will garner significant public benefits while presenting minimal safety risks.

Focus-On-Video, LLC petition satisfies the criteria of Section 333 of the FMRA and is substantially 

similar to previous petitions the FAA has granted, meriting a summary grant of exemption. FocusOn-Video, LLC respectfully requests that the FAA grant this petition to enhance Focus-On-Video, 

LLC ability to provide wedding and event photography and videography to its customers.

Sincerely,

Bernard McRae

Focus-On-Video, LLC

Bernard@Focus-On-Video.com