Double	I	Media,	LLC

Attn:	David	Agler,	Owner

210	Charring	Cross	Dr	S

Westerville,	OH	43081

614-638-2508

dave@doubleimedia.com

www.doubleimedia.com

February	24, 2016

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue

SE	Washington,	DC	20590

Subject:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11.61 of	the

Federal	Aviation	Regulations	from	14	C.F.R.	Parts 21,	(h),	91.203(a)&(b),	91.9,	45.23,	

45.27(a),	45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1),	

(b)(2),		91.105,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405,	

91.407,	91.409,	&	91.417

Pursuant	to	Section	333	of the	FAA	Modernization	and	Reform	Act	of	2012	and	14

C.F.R.	Part	11.61,	Double	I	Media,	LLC,	respectfully seeks an	exemption	from	the	following	

Code	of	Federal Regulations	(C.F.R.)	to	be	allowed	commercial	operation	of	lightweight	

Unmanned Aircraft	Systems (UAS)	for:

 aerial	imaging	and	videos	for	inspection	and	sale	of	real	estate,	

 inspection	of	structures	for	engineering	and	architectural	purposes

 closed	set	commercial	and	film	production

 video	and	still	image	production	for	advertising	and	other	business	needs

 inspection	and	survey	of	wildlife,	plant,	and	other	resources	for	land	management

 mapping,	inspection,	and	survey	of	open	mining	and	landfill	operations

 mapping,	inspection,	and	survey	of	utilities,	gas,	and	oil	facilities

 mapping,	inspection,	and	survey	of	agriculture

 mapping,	inspection,	and	survey	of	construction	sites

 mapping,	inspection,	and	survey	of	disaster	areas

Double	I	Media,	LLC,	respectfully	seeks	an	exemption	from	the	following	Code	of	Federal	

Regulations	(C.F.R.):	14	C.F.R. Parts 21,	(h),	91.203(a)&(b),	91.9,	45.23,	45.27(a),	

45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1),	(b)(2),		
91.105,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405,	91.407,	

91.409,	&	91.417

This	exemption	request	seeks	permission	to	operate	for	commercial	purposes	the	Phantom	

3	Pro	and	Inspire	1	models	of	UAS	manufactured	by	DJI.	These	are	highly	reliable	industrystandard	platforms	and	have	been	approved	for	use	under	numerous exemptions	already	

granted	according	to	the	criteria	detailed	in	Section 333 of Public Law 112−95.

Double	I	Media,	LLC,	and	any	pilots	and/or	other	personnel	it employs in	the	operation	of	

an	UAS	in	the	NAS,	will	abide	by	all	FAA	requirements from	which	relief	has	not	been	

granted	by	this	requested	exemption,	to	ensure	this exemption	will	provide	a	level	of	safety	

at	least	equal	to	existing	rules	and	will	only operate	in	safe	environments that	are	strictly	

controlled,	are away	from	aerial navigation	hazards,	power	lines, elevated	lights,	airports	

and	highly populated	areas. All	participating	persons	employed	by Double	I	Media,	LLC, and	

any	other	operational	and/or	participating	personnel, will	conduct	all preflight	inspections	

and	preparations	as	are	necessary	to	guarantee	the	safe	and	proper	operation	of	the	UASs.	

Requests	for	Relief

14	C.F.R.	Parts 21,	(h),	91.203(a) & (b),	91.9

Due	to	the	weight,	dimensions,	velocity,	and	limited	area	of	operation	associated	with	the	

UASs	referenced	in	this	request,	relief	from	14	CFR	part	21,	Subpart	H,	91.203	(a)	and	(b),	

and	91.9	is	requested.	

The	UASs	to	be	used	weight	less	than	55	pounds,	are	powered	by	electric	motors,	carry	no	

flammable	liquids	or	fuel,	carry	no	passengers	or	cargo,	are	constructed	largely	of	plastic	

and	other	flexible	materials,	and	will	be	operated	in	environments	under	observation	by	

one	or	more	persons	other	than	the	PIC	(Pilot	in	Control).	

Given	all	of	these	details,	the	UASs	are	able	to	operate	with	at	least	an	equivalent	level	of	

safety	as	other	aircraft.	Additionally,	the	UASs	will	not	receive	a	traditional	certificate	of	

airworthiness,	and	will	have	no	internal	space	to	display	or	carry	documents.	A	copy	of	the	

certificate	of	authorization	and	all	operator	manuals	will	be maintained	with	the	other	

required	records	held	by	the	PIC	in	the	area	of	operation	for	each	mission.

14	C.F.R.	Parts 45.23,	45.27(a),	45.29(3)(c)(d)(e)(f)(g)(h)	

Due	to	the	small	size	of	the	UASs,	relief	is	requested	from	14	C.F.R.	Parts	45.23,	45.27(a),	

and	45.29(3)(c)(d)(e)(f)(g)(h).	There	is	very	little	space	upon	which to	place	markings,	and	

given	the	small	size	of	the	UASs,	it	is	unlikely	that	any	markings	made	would	be	legible	

while	in	operation.	All	UASs	will	be	marked	with	an	N	number	displayed	legibly	in	the	

largest	possible	size	characters	so	that	they	may	be properly	identified.	However,	due	to	
the	very	small	size	of	the	UASs,	markings	as	described	in	14	C.F.R.	Parts	45.23,	45.27(a),	

and	45.29(3)(c)(d)(e)(f) (g)(h) are	not	practical.	

14	C.F.R.	Parts	61.3,	61.133(a),	and	61.113	(a)	&	(b)

Due	to	the	small	weight	and	size,	lack	of	combustible	fuel,	crew,	passengers,	and	cargo,	

relief	is	requested	from	14	C.F.R.	Parts	61.3,	61.133(a),	and	61.113	(a)	&	(b). A	commercial	

pilot	certification will	not	train	the	PIC	(Pilot	in	Control)	in	the	safe	and	competent	

operation	of	a	UAS.	Furthermore,	given	the	characteristics	of	the	UASs,	the	skills	obtained	

by	qualifying	for	a	commercial	pilot	certification	are	not	necessary	to	operate	the	UASs,	in	a	

manner	that	does	not	endanger	or	conflict	with	other	aircraft	operating	in	the	NAS,	and	

does	not	endanger	persons	or	property	on	the	ground.	

14	C.F.R.	Part	91.103,	(b)(1),	(b)(2)

Relief	is	requested	from	14	C.F.R.	91.103,(b)(1),(b)(2)	due	to	the	fact	that	UASs	operations	

are	not	conducted	near,	and	are	prohibited	from	taking	place	at,	airports.	An	appropriate	

measure	of	safety	will	be	provided	by	completing	preflight	actions	as	described by	the	

manufacturer’s	manuals.

14	C.F.R.	Parts	91.105	

The	UASs does	not	carry	a	crew,	so	there	are	no	crewmembers aboard,	and	no	stations	to	

be	manned.	The	actions	of	the	PIC	are	required	to	operate	the	UASs,	so	the	pilot	must	

maintain	contact	with	and	control	of	the	Remote	Controller	at	all	times	during	flight.	The	

PIC	will	not	change	during	operation	of	the	UASs,	and	both	the	PIC	and	Safety	Observer	will	

always	be	clearly	identified	prior	to	the	start	of	each	mission.	

14	C.F.R.	Parts	91.109(a)	&	91.319(a)(1)

The	UASs	does	not	have	a	crew,	and	for	this	reason	there	is	no	seatbelt	or	restraint	

necessary	to	the	safe	operation	of	the	UASs.	The	UASs	is	controlled	by	a	single	controller,	so	

dual	control	is	not	an	option	for	training.	All	training	missions	for	new	pilots	will	be	

conducted	at	low	altitudes	in	remote	locations	away	from	uninvolved	persons	and	

property.	

14	C.F.R.	Part	91.119

Given	the	size,	weight,	flight	characteristics,	and	lack	of	combustible	fuel	or	payload,	relief	

from	the	500	foot	distance	requirement	is	requested.	The	UASs	operations	pose	little	risk	

to	persons	in	the	area	of	operation.	All	operations	will	be	conducted	with	the	consent	of	the	

property	owner,	and	all	persons	operating	or	that	have	property	in	the	operating	area	will	

be	made	aware	of	the	operations,	and	all	reasonable	measures	will	be taken	to	ensure	that	
persons	and	property	in	the	area	of	operation	are	at	the	least	possible	risk	of	contact	with	

the	UASs.	Additionally,	the	missions	the	UASs	will	fly	do	not	require	achieving	altitudes	of	

more	than	400	feet	AGL.	

14	C.F.R.	Part	91.121	

The	UASs	utilize	a	barometric	pressure	sensor,	and	GPS	systems	to	calculate	the	altitude.	

These	are	self-calibrated	by	the	flight	systems	of	the	UASs	and	require	no	manual	reset	or	

synchronization	with	secondary	ground-based	systems	and/or	nearby	airports.	

Additionally,	the	UASs	will	only	be	operated	under	400	feet	AGL.	As	such,	relief	is	requested	

from	14	CFR	91.121.	

14	C.F.R.	Part	91.151,(a)	91.151(b)		

The	UASs	use	electric	motors	powered	by	batteries,	and	as	such,	do	not	carry	fuel.	The	

maximum	length	of	operation	on	a	single	charge	is	not	more	than	20	minutes.	For	this	

reason,	relief	is	requested	from	14	CFR	91.151,	as	the	operational	characteristics	of	the	

UASs	do	not	permit	flight	for	the	duration	required	by	the	regulation.	Given	the	very	small	

area	of	operation	and	the	size	of	the	UASs,	an	equivalent	level	of	safety	will	be	achieved	by	

ensuring	that	the	battery	is	at	full	charge	at	takeoff,	and	missions	are	terminated	when	the	

battery	charge	reaches	25%.	

14	C.F.R.	Parts	91.405,	91.407,	91.409,	&	91.417	

As	the	UASs	in	service	are	simple	machines	of	a	small	size	and	uncomplicated	nature,	relief	

is	requested	from	14	CFR	91.405,	91.407,	91.409,	and	91.417.	The	PIC	will	perform	a	

preflight	inspection	prior	to	the	start	of	each	mission.	Any	required	simple	maintenance	

will	be	completed	and	documented	by	the	PIC.	Any	regular	maintenance	or	detailed	

inspection	mandated	or	recommended	by	the	manufacturer	will	be	performed	by	qualified	

personnel	at	the	place	of	purchase	of	the	UASs,	and	documented	by	the	PIC.	
Conclusion

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14

C.F.R.	Part	11.61,	Double	I	Media,	LLC,	respectfully	seeks	an	exemption	from	the	following	

Code	of	Federal	Regulations	(C.F.R.)	to	be	allowed	commercial	operation	of	lightweight	

Unmanned	Aircraft	Systems	(UAS)	for:

 aerial	imaging	and	videos	for	inspection	and	sale	of	real	estate,	

 inspection	of structures	for	engineering	and	architectural	purposes

 closed	set	commercial	and	film	production

 video	and	still	image	production	for	advertising	and	other	business	needs

 inspection	and	survey	of	wildlife,	plant,	and	other	resources	for	land	management

 mapping,	inspection,	and	survey	of	open	mining	and	landfill	operations

 mapping,	inspection,	and	survey	of	utilities,	gas,	and	oil	facilities

 mapping,	inspection,	and	survey	of	agriculture

 mapping,	inspection,	and	survey	of	construction	sites

Double	I	Media, LLC,	respectfully	seeks	an	exemption	from	the	following	Code	of	Federal	

Regulations	(C.F.R.): 14	C.F.R.	Parts 21,	(h),	91.203(a)&(b),	91.9,	45.23,	45.27(a),	

45.29(3)(c)(d)(e)(f)(g)(h),	61.3,	61.133(a),	and	61.113	(a)	&	(b),	91.103,	(b)(1),	(b)(2),		

91.105,	91.109(a)	&	91.319(a)(1),	91.119,	91.121,	91.151,(a)	91.151(b),	91.405,	91.407,	

91.409,	&	91.417

Respectfully	submitted,

Double	I	Media,	LLC

Attn:	David	Agler,	Owner

210	Charring	Cross	Dr	S

Westerville,	OH	43081

614-638-2508

dave@doubleimedia.com

www.doubleimedia.com