FEDERAL AVIATION

ADMINISTRATION EXEMPTION

Petition for Exemption under Section 333

Submitted by: Joshua Chamberlain/Stickman Productions, LLC

Date 6/22/2015

Stickman Productions, LLC - Petition for Exemption
CONTACT INFORMATION

Exemption Applicant:

STICKMAN PRODUCTIONS, LLC, 

signed by Joshua Chamberlain

Exemption Company:

STICKMAN PRODUCTIONS, LLC

Exemption Applicant Address:

290 Powell Circle

Berlin, MD 21811

Phone:

310.694.7632

www.StickmanProductions.biz

Stickman Productions, LLC - Petition for Exemption
UAS OWNED AND OPERATED

OPERATION MANUAL: http://download.dji-innovations.com/downloads/

phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.6_en.pdf

QUICK START GUIDE: http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_Quick_Start_en.pdf

TRAINING GUIDE: http://download.dji-innovations.com/downloads/phantom-2-vision/

en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf

Protocols and Controls 

Aerial Community and Real Estate Videos 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. 

Pre-Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries 

for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

Stickman Productions, LLC - Petition for Exemption
Check weather forecasts for wind advisory or other conditions that my impact flight. Consult five 

(5) mile radius map for airport vicinity. 

o Contact respective airport to advise of estimated flight time, estimated flight duration, 

estimated elevation of flight, and any other pertinent information. 

Inspect flight area for 

o vicinity of public safety helipads/heliports 

o vicinity of medical helipads/heliports 

o vicinity of light poles o vicinity or utility wires o vicinity of trees 

o flocks of birds that may cause interference and potential flight impact 

o vicinity of any elevated obstructions that may pose potential flight hazard o vicinity of 

roadways with moderate to heavy traffic that can be distracted o public gatherings that may 

attract viewers 

o optional point of control for best visual site of UAS while in flight Takeoff and landing 

o inspect area for best and safest point of takeoff and landing 

o if in a subdivision or area that is within 150 feet of a residential street, post warning sign(s)/

stand(s) "Attention Aerial Photography In Progress - Remain Back 150 Feet " 

Flight Protocol: 

Takeoff and land from same location 

Remain alert to birds, sound or aircraft, curious public, and approaching vehicles Do not allow 

anyone to engage in conversation or distract the remote control pilot Restrict flight to minimal 

elevation sufficient to acquire desired results 

Remained prepared for emergency landing at all times Pay attention to flight time 

o If possible set a timer as a safety alert 

Land UAS and shut down propulsion immediately following landing 

Protocols and Controls 

Aerial Community 

Post flight: 

a. disconnect battery to prevent accidental activation of propulsion system 

b. secure UAS in a safe location 

c. remove all warning signs from public access areas 

Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

o manned aircraft is heard or seen in vicinity of flight 

o there is a public gathering within established safety boundary wanting to observe flight 

o pilot is being distracted from focusing on flight and safety 

o sudden change in weather (wind bursts) 

o sudden increase in vehicular traffic in vicinity of flight 

o birds enter into proximity of flight 

o any sudden unsafe event that can cause collision, distraction or interruption of control 

o always have a first aid kit on hand 

Stickman Productions, LLC - Petition for Exemption
SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS FROM 

WHICH Joshua Chamberlain, Stickman Productions, LLC request exemptions:

14 CFR 21;

14 C.F.R. 45.23(b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

Stickman Productions, LLC - Petition for Exemption
The extent of relief Joshua Chamberlain seeks and reason I seek the relief:

I, Joshua Chamberlain, submit this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to 

prevent me, Joshua Chamberlain, contemplated commercial photographic, cinematic, 

academic and other flight operations within the national airspace system. The Reform 

Act in Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public’s interest to do so.

My, Joshua Chamberlain’s, ultra lightweight UAS Phantom 2 meets the definition of 

“small unmanned aircraft” as defined in Section 331 and therefore the integration of my 

ultra light weight UAS is expressly contemplated by the Reform Act. I would like to 

operate my ultra lightweight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft. Thereby, providing direct 

experience and valuable information for formal regulation that can be administered 

uniformly to all real estate related UAS aerial video and photography. The Reform Act 

guides the Secretary in determining the types of UAS's that may operate safely in

our national airspace system. Considerations include: The weight, size, speed and 

overall capabilities of the UAS's; Whether the UAS will be operated near airports or 

heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 

P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Joshua 

Chamberlain. My UAS utilizes four (4) counter-rotating propellers for balance, control 

and stability. My UAS is equipped with GPS and auto return safety technology, geofencing technology, and battery monitoring technology with a fail-safe to automatically 

return to landing point if battery is running under 10%. Weighing less than five (5) 

pounds (far below the maximum UA limit); including camera with gimbal, this aircraft is 

extremely lightweight.

I, Joshua Chamberlain, consider safety foremost with each flight. My small unmanned 

aircraft is designed to hover in place via GPS and operate in less than a 24 knot wind. I 

also use geo-fencing, to limit the altitude and perimeter of flight. For safety, stability and 

fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety 

systems include a GPS mode that allows my UAS to hover in place when radio controls 

are released. When pilot communication is lost this UAS is designed slowly descend to 

point of take off. 

I do not operate my UAS without my “spotter” who is observant with me on full line of 

sight. I do not operate my UAS near airports, hospitals nor Police heliports, public 

places such as stadiums and do not operate near areas where general public is within 

fifty to one hundred (50-100) yards depending on location, conditions and weather. I 

operate only in class G airspace. I use a visual observer to aid in ensuring the area is 

clear of people and vehicles. I am constantly on alert for any manned aircraft (police/

medical helicopters, etc.) and I am prepared to land/abort immediately to the nearest 

and safest ground point should a manned aircraft approach my location or I suspect 

manned aircraft may approach near my location. I monitor local ATC frequencies on a 

handheld aviation radio. My UAS is capable of vertical and horizontal operations, and is 

flown only within my line

Stickman Productions, LLC - Petition for Exemption
of sight of me, as the remote control pilot. Utilizing battery power rather than 

combustible fuels, flights generally last between seven (8) to ten (10) minutes, with an 

altitude under 200 feet. I, Joshua Chamberlain, utilize a fresh fully charged battery with 

each flight as a safety precaution; full flight time limit for each battery is twenty (20) to 

twenty five (25) minutes as tested. My controller and link with my UAS provides battery 

level information, and also has an automatic return to home feature at 20% battery 

power in the event the PIC fails to monitor reserves, along with visual and auditory 

alerts at 20%. I do not operate my UAS at or below manufacturer recommend minimum 

charge levels for operation; preferring to remain well within a safe operating range to 

insure adequate communication between radio control and UAS to eliminate potential 

for crash, loss of control or hazard. 

My personal protocol is land with 40% reserves. Additional batteries (5200mAh LiPo) 

are at hand with each exercise to insure replacement for sufficient safe level of 

operation. I have roughly 10 years of experience operating UAS aircraft as a hobbyist 

with over 50 hours of unlogged hours to learn familiarization with the characteristics of 

this specific UAS's performance under different temperature and weather conditions. As 

well as practicing safe landing and take-off positions.

My, Joshua Chamberlain, exemption request would allow operation in predetermined 

areas designated as class G airspace, clear of persons, airports, heliports and vehicular 

traffic for community videos and photos. Real estate photography/videography would be 

within property boundaries of individual homeowner, and/or over adjacent waterways or 

vacant land, when deemed clear of any and all persons, vehicles or marine traffic . A 

visual observer “spotter” would be present for all flights to ensure the area remains 

clear, or to alert me, the PIC, to abort the flight of a potential breach of the flight area. 

A 2 way aviation radio would be monitored at all times.

A NOTAM would be issued prior to any operations. A thorough review of weather 

conditions, aircraft airworthiness, emergency procedures and potential hazards would 

be reviewed prior to any flight operation. Geofencing would be used to ensure all flights 

are conducted within the established, cleared perimeter.

I, Joshua Chamberlain, am extremely cautious when operating of my UAS/ultra 

lightweight unmanned aircraft and will not “create a hazard to users of the national 

airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of 

my UAS it falls well within Congress’s contemplated safety zone when it promulgated 

the Reform Act and the corresponding directive to integrate UAS's into the national 

airspace system. Joshua Chamberlain UAS, used in hobby flight, has a demonstrable 

safety record and does not pose any threat to the general public or national security.

Stickman Productions, LLC - Petition for Exemption
How Joshua Chamberlain request will benefit the public as a whole:

• On a smaller, more affordable budget, companies in my area will be able to obtain 

aerial videography which will be more cost prohibitive.

• I will be able to employ “Spotters” and provide jobs to my local community

• Footage shot by UA would be in need of post-production creating more jobs for the 

community

• I intend on setting the example on how to properly insure, monitor and fly my UAS.

• UAS is battery powered and creates no emissions that can harm the environment

• USA can give media access to hard-to-reach places

• The weight and size of my, Joshua Chamberlain, UAS is far less than a full size 

helicopter or aircraft; which can cause catastrophic devastation to public.

• Aerial videos would inspire and motivate community members to explore their cities 

and towns.

• Too many UA fliers in the area are flying without FAA approval - I plan on setting the 

bar with my strict discipline to the FAA rules and regulations.

Stickman Productions, LLC - Petition for Exemption
Reasons Why Joshua Chamberlain’s exemption will not adversely affect safety or 

how the exemption will provide a level of safety at least equal to existing rule:

My, Joshua Chamberlain’s, exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated permitting me, Joshua Chamberlain, to log more flight time in FAA 

controlled airspace, with communication with the FAA, will allow me to contribute to the 

innovation and implementation of new and novel, as of yet undiscovered safety protocols for

In addition I, Joshua Chamberlain, submit the following representations of enhancements to 

current aerial videography and photography for television, motion picture, commercial and 

real estate: 

• My UAS weighs 1160g (including battery and propellers) with a small ultralight weight high 

quality integrated camera; 

• My UAS includes radar positioning and return to home - meaning the UA will automatically 

fly back to its takeoff point and land safely.

• My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost;

• I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012); 

• My UAS will only operate no more than 20 minutes per flight

• I land my UAS prior to manufacturer recommended minimum level of battery power (40%); 

• I always obtains all necessary permissions prior to operation as well as respect 

neighboring observants

• I pilot my UAS through remote control only by line of sight; 

• I actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols; 

• I only operate in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports, animals and actively populated areas; 

• I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance; 

• I have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

• My UAS will be properly insured by Atlantic/Smith, Cropper & Deeley. aacd.net

Stickman Productions, LLC - Petition for Exemption
My, Joshua Chamberlain’s, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent the integration of commercial UAS into our 

national airspace system, helicopters are the primary means of aerial video and 

photography for community awareness and real estate. While the safety record of such 

helicopters is remarkably astounding, it is far safer to operate a battery powered ultralight 

weight UAS. 

• First, the potential loss of life is diminished because UAS's carry no people on board and I 

only operate my UAS in specific areas away from mass populations. 

• Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. 

• Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot 

away from and avoid hazards quickly and safely. 

• Lastly, given its small size and weight, even when close enough to capture amazing 

images, my UAS need not be so close to the objects they are focused on through the 

technology and use of post editing software allowing pan and zoom. 

Accordingly, my UAS has been experimentally operated for familiarization/competency and 

will continue to operate at and above current safety levels. 

Stickman Productions, LLC - Petition for Exemption
VI. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The 

size, weight and enclosed operational area of my, Joshua Chamberlain’s, UAS permits 

exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from 

the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's 

from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My, Joshua 

Chamberlain’s, current and projected UAS's meet or exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. 

An equivalent level of safety will be achieved by maintaining a safety/flight manual 

delineating areas of where safety can be defined.10 The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by 

me, Joshua Chamberlain. 

B. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft with dimensions smaller that minimal lettering 

requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the 

word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. 

§45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the 

markings. The FAA has previously issued exemptions to this regulation through Exemptions 

Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Joshua Chamberlain, can achieve an equivalent level of safety as achieved by 

current Regulations because my UAS does not carry any pilots or passengers. Further, while 

helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the 

operation of my UAS is far less than the risk levels inherent in the commercial activities outlined 

Stickman Productions, LLC - Petition for Exemption
in 14 C.F.R. § 61, et seq. Thus, allowing me, Joshua Chamberlain, to operate my UAS meet and 

exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at 

an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Joshua Chamberlain, 

will however operate my UAS in safe areas away from public and traffic, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be 

achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] 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. . . .” 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Joshua Chamberlain’s, UAS. However, as a safety precaution I inspect 

my UAS before and after each flight. 

A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 

C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The 

size, weight and enclosed operational area of my UAS permits exemption from Part 21 

because my, Joshua Chamberlain’s, UAS meets an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My UAS 

meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an 

aircraft without an airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety will 

be achieved. 

Stickman Productions, LLC - Petition for Exemption
In summary, Joshua Chamberlain seeks an exemption from the following 

Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 

91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Joshua 

Chamberlain's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness and real estate operations, and to develop economic platforms for real estate to 

enhance the experience of those seeking to relocate to the metro Raleigh area. Currently, 

area awareness and real estate aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Therefore posing potential risk to the public. 

Granting my, Joshua Chamberlain’s, request for exemption will reduce current risk levels 

and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is 

smaller, lighter and more maneuverable than conventional real estate video and 

photographic aircraft with much less flight time. Further, I operate at lower altitudes and in 

controlled airspace eliminating potential public risk flying to and from established air fields. I, 

Joshua Chamberlain, have been informally analyzing flight information and will compile 

safety protocols and the implementation of a flight operations manual for real estate usage 

that exceeds currently accepted means and methods for safe flight. Formal collection of 

information shared with the FAA will enhance the FAA's internal efforts to establish protocols 

for complying with the FAA Modernization and Reform Act of 2012. There are no personnel 

on board my, Joshua Chamberlain’s, UAS and therefore the likelihood of death or serious 

bodily injury is significantly diminished. My, Joshua Chamberlain’s, operation of my UAS, 

weighing less than 5 pounds and traveling at lower speeds within limited areas will provide 

an equivalent level of safety as that achieved under current FARs. Accordingly I, Joshua 

Chamberlain, respectfully request that the FAA grant my exemption request and am willing 

to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the 

general public at large. 

Respectfully submitted, 

Joshua Chamberlain 

President 

Stickman Productions, LLC 

290 Powell Circle 

Berlin MD 21811 

Stickman Productions, LLC - Petition for Exemption
ADDITIONAL INFORMATION: 

Checklist used by JOSHUA CHAMBERLAIN: 

Stickman Productions, LLC - Petition for Exemption
Additional Resources: 

http://knowbeforeyoufly.org/

http://www.dji.com/newpilot

https://www.youtube.com/channei/UCRjoWtWg9BPyZK8YxMrH2Zw

http://www.modelaircraft.org/

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

http://www.dii.com/product/phantom-2/spec

http://www.dii.com/support

http://wiki.dii.com/en/index.php/Phantom 2

http://wiki.dji.com/en/index.php/Phantom 2 Vision%2B Flight Limits

http://www.dji.com/newpilot

Stickman Productions, LLC - Petition for Exemption