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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

VIDEOLYZERS INC and MICHAEL REID

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 

91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF FREEFLY 

CINESTAR 8, FREEFLY ALTA, AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on September 30th, 2015

VIDEOLYZERS INC and

MICHAEL REID

27 Castle Harbour Drive

Port Perry, Ontario, Canada

647-262-8987 

Mikegwreid@gmail.com
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TABLE OF CONTENTS

 Page

GLOSSARY OF 

ABBREVIATIONS...................................................................................................3

SUMMARY.............................................................................................................4

INTRODUCTION AND INTERESTS OF 

PETITIONER...........................................................................................................4

BACKGROUND.......................................................................................................4

BASIS FOR 

PETITION................................................................................................................5

NAME AND ADDRESS OF 

PETITION.............................................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VIDEOLYZERS INC AND 

MICHAEL REID SEEKS 

EXEMPTION...................................................................................6

THE EXTENT OF RELIEF VIDEOLYZERS INC AND MICHAEL REID SEEKS AND 

THE

REASON VIDEOLYZERS INC AND MICHAEL REID SEEKS THE 

RELIEF...........................................10

THE REASONS WHY GRANTING VIDEOLYZERS INC AND MICHAEL REID’S 

REQUEST

WOULD BE IN THE PUBLIC INTEREST ..................................................................12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY...........................................................................23

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..............29

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT VIDEOLYZERS INC AND MICHAEL REID

REQUEST.................................29

CONCLUSION......................................................................................29

APPENDICES.......................................................................................31
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

VIDEOLYZERS INC AND MICHAEL REID seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit VIDEOLYZERS INC 

AND MICHAEL REID to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography for documentary

and television filming purposes.

Regulations from which the exemption is requested : 

14 CFR 61.113 (a) and (b) 

14 C.F.R 91.103 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 CFR. 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) and (b)

14 CFR 91.203 (a) and (b) 

14 CFR 91.715 

UASs operated by Videolyzers weigh less than 55 pounds, including all payload. The 

operate at speeds of less than 50 knots, can hover, and can simultaneously move in 

multiple directions. Shy Shots will only operate its UASs in line of sight and will operate 

only within the sterile environment described in the FOPM. Such operations will insure 

that the UAS will not create a hazard to users of the NAS or public.

Given the small size of our UASs and the restricted area that they will be operated, Sky 

shot’s UAS operations adhere to the Reform Act’s safety requirements. 

Additionally, due to the size of the UASs and the limited area in which they will operate, 

approval of this application presents no national safety concerns. Based on the substantial 

level of safety surrounding the proposed operations, and the significant public benefit 

(enhanced safety). Reduction in environmental impacts in the outdoor setting these UASs 

will operate leaving no trace of activity behind, the grant of the requested exemption is in 

the public interest. Accordingly, Sky Shots respectfully requests that the FAA grant the 

requested exemption.

INTRODUCTION AND INTERESTS OF THE PETITIONER

MICHAEL REID is a documentary filmmaker who has 8 years of experience in film and 

television, and 3 years of experience in building, flying, and maintaining UAV’s for 

aerial filming. MICHAEL REID has over 400 of hours flying experience, and over 3 
6

years recreational/hobby experience operating Unmanned Aircraft Systems (UAS). The 

objective of MICHAEL REID and his aerial operations is to provide high quality imaging 

for a variety of commercial doumentary and television uses.

BACKGROUND

Unmanned Aircraft Systems: Freefly Cinestar 8, Freefly Alta , DJI Inspire 1 UASs

VIDEOLYZERS INC AND MICHAEL REID seeks an exemption to operate DJI and 

Freefly systems UAV’S for compensation or hire within the NAS. The Freefly 

Cinestar 8, Alta, and DJI Inspire 1 are vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. The Freefly Cinestar 8 has a maximum gross weight of 

approximately 40 pounds, while having a length of 40 inches width of 40 inches, 

height of 15 inches, and a maximum speed of approximately 31 knots. 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 Freefly Cinestar 8, Freefly Alta are equipped with 8 

rotors, and DJI Inspire 1 is equipped with four rotors; driven by Lithium Polymer 

battery powered electric motors.

The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs that will be operated by 

VIDEOLYZERS INC AND MICHAEL REID will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

BASIS FOR PETITION

Petitioner, VIDEOLYZERS INC AND MICHAEL REID, pursuant to the provisions 

of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization 

and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially 

operate the Freefly Cinestar 8, Freefly Alta,, DJI Inspire 1 UASs in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b).
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In consideration of the speed, weight, size, and limited operating area associated with 

the unmanned aircraft and its operation, VIDEOLYZERS INC AND MICHAEL REID

operation of Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, VIDEOLYZERS INC AND MICHAEL REID requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set 

forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate.

VIDEOLYZERS INC AND MICHAEL REID submits that the requested relief is 

proper since an equivalent level of safety will be ensured. VIDEOLYZERS INC AND 

MICHAEL REID will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 Instruction 

Manual). Furthermore, VIDEOLYZERS INC AND MICHAEL REID will document 

and maintain all maintenance records for the Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by VIDEOLYZERS INC 

AND MICHAEL REID to the extent necessary to allow a Pilot in Command (PIC) 

holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the Freefly Cinestar 8, Freefly Alta, 

and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

VIDEOLYZERS INC AND MICHAEL REID seeks relief from Section 91.7(a), 

entitled Civil aircraft airworthiness, because the Freefly Cinestar 8, Freefly Alta, and 

DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, VIDEOLYZERS INC AND MICHAEL REID

submits that he will ensure that the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 

1UASs are in an airworthy condition, prior to every flight, by determining that the 

UASs are in compliance with the operating documents (i.e., Monthly Maintenance 

Log, and Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight.

VIDEOLYZERS INC AND MICHAEL REID also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UAs will not have a typical barometric altimeter 

onboard. However, altitude information of the Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path. This altitude information, 
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combined with VIDEOLYZERS INC AND MICHAEL REID’s operation of the Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs within visual line of sight, at or below 

500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, VIDEOLYZERS INC AND MICHAEL REID seeks an exemption from 

the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. VIDEOLYZERS INC AND MICHAEL REID submits that safety will not 

be affected by operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs 

during daylight hours in visual meteorological conditions (VMC) under visual flight 

rules (VFR), with enough battery power to fly for a total duration of approximately 

13.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, VIDEOLYZERS INC AND 

MICHAEL REID provides the following information in support of its 

petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

VIDEOLYZERS INC AND MICHAEL REID

27 Castle Harbour Drive

Port Perry, Ontario, Canada

L9L 1P4

647-262-8987

Mikegwreid@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which VIDEOLYZERS INC 

AND MICHAEL REID Seeks Exemption.

1. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft 

in connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.
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2. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states 

the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, 

in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation 

of the departure airport or an appropriate altimeter setting available 

before departure.

4. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after 

that for at least 20 minutes.

5. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirement Of

Section 91.405(a).
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Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) 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[.]

6. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From 

The Requirements Of

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

8. VIDEOLYZERS INC AND MICHAEL REID Seeks Exemption From The 

Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state 

the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 
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approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the 

time since the last inspection required by the inspection program 

under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the 

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired and 

the aircraft is approved for return to service.
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C. The Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID

Seeks And The Reason VIDEOLYZERS INC AND MICHAEL REID

Seeks The Relief.

1. Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID

Seeks And The Reason VIDEOLYZERS INC AND MICHAEL 

REID Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct 

the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, VIDEOLYZERS INC AND MICHAEL REID

submits that an equivalent level of safety will be maintained because no PIC will 

be allowed to operate the Freefly Cinestar 8, Freefly Alta,

UAS or DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the Freefly 

Cinestar 8, Freefly Alta, or DJI Inspire 1 UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.

Further, VIDEOLYZERS INC AND MICHAEL REID submits that all flights of 

the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to 

VIDEOLYZERS INC AND MICHAEL REID’s business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID Seeks 

And The Reason

ALON

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow VIDEOLYZERS INC AND MICHAEL REID to determine that 
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the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs are in airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the VIDEOLYZERS INC AND MICHAEL REID Aerial Operations 

Manual, Monthly Maintenance Log, and Freefly Cinestar 8, Freefly Alta, and DJI Inspire 

1 Instruction Manual).

VIDEOLYZERS INC AND MICHAEL REID seeks the requested relief because the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, VIDEOLYZERS 

INC AND MICHAEL REID will ensure that the Freefly Cinestar 8, Freefly Alta, and 

DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Freefly Cinestar 8, Freefly 

Alta, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine 

that the aircraft are in condition for safe flight, as stated in the conditions and limitations 

below.

3. Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID

Seeks And The Reason VIDEOLYZERS INC AND MICHAEL 

REID Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control 

station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), 

VIDEOLYZERS INC AND MICHAEL REID seeks the requested relief because the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs are equipped 

with a barometric pressure sensor and GPS equipment, which automatically ensures that 

a ground level pressure setting will be established prior to each flight, and provides the 

PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID Seeks And The 

Reason ALON

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to 
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the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 4.5 minutes. VIDEOLYZERS INC AND MICHAEL REID seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs 

will severely constrain the practicality of any aerial video or still photo

flight operations that VIDEOLYZERS INC AND MICHAEL REID proposes to 

conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs, the Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 operating documents, and VIDEOLYZERS INC AND MICHAEL REID’s 

proposed operating limitations, ensure that VIDEOLYZERS INC AND MICHAEL 

REID will safely operate the battery powered Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes.

5. Extent Of Relief VIDEOLYZERS INC AND MICHAEL REID

Seeks And The Reason VIDEOLYZERS INC AND MICHAEL 

REID Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, VIDEOLYZERS INC AND 

MICHAEL REID requests relief from these Sections because the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs do not require airworthiness certificates. As set 

forth more fully below, the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs 

meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, VIDEOLYZERS INC AND MICHAEL REID will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the VIDEOLYZERS INC AND MICHAEL REID Aerial Operations 

Manual, Monthly Maintenance Log, and Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 Instruction Manual). Furthermore, VIDEOLYZERS INC AND MICHAEL 

REID will document and maintain all maintenance records for the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs.

D. The Reasons Why Granting VIDEOLYZERS INC AND MICHAEL REID

Request Would Be In

the public interest
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Granting the present Petition will further the public interest by allowing 

VIDEOLYZERS INC AND MICHAEL REID to safely, efficiently, and 

economically perform aerial video and photography and documentary filming over 

certain areas of the United States.

Additionally, use of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of VIDEOLYZERS INC AND MICHAEL REID’s 

proposed operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will 

be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs are battery powered and 

serve as a safe, efficient, and economical alternative to the manned aircraft traditionally 

utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing the use of a Freefly Cinestar 8, 

Freefly Alta, or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety of life and property in 

the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 2 and DJI Inspire 1 UAs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs produce no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the

UAs are propelled by battery powered electric motors, rather than an internal 

combustion engine.

By using the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which is 
16

usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs 

(weighing approximately 25 pounds, 22 pounds, and 6 pounds 7.5 ounces respectively, at 

their maximum gross weights with lengths of 40 inches and 17.3 inches respectively, 

widths of 40 inches and 17.7 inches respectively, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs Will Benefit 

The Economy.

In addition to being safe and efficient, the Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the Freefly Cinestar 8, Freefly Alta, and 

DJI Inspire 1 UASs will allow United States based companies, like VIDEOLYZERS INC 

AND MICHAEL REID, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered Freefly Cinestar 8, Freefly Alta, and 

DJI Inspire 1 UASs is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft.

By operating the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, companies 

such as VIDEOLYZERS INC AND MICHAEL REID, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, 

which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both 

in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, VIDEOLYZERS INC AND MICHAEL REID’s proposed operation of the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will not implicate any privacy 

issues. Specifically, the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will be 

operated only in compliance with operating documents (i.e., the VIDEOLYZERS INC 
17

AND MICHAEL REID Aerial Operations Manual, Monthly Maintenance Log, and 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which VIDEOLYZERS INC AND MICHAEL REID

Seeks Exemption.

1. Reasons Why The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UAs Meet The Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, VIDEOLYZERS INC AND MICHAEL 

REID’s operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs meet 

the conditions of FMRA Section 333, and will not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security. Specifically, 

FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the Secretary 

of Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum--

(1) which types of unmanned aircraft systems, if any, 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; and
18

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, VIDEOLYZERS INC AND MICHAEL REID submits that 

the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs; (b) the pilot certification 

requirement; and (c) the specific operating limitations.

a. The Specifications Of The Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 UASs Demonstrate Its Safe Characteristics.

The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs do not create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The Freefly Cinestar 8, Freefly Alta, 

and DJI Inspire 1 UASs.

The technical specifications of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UASs are set forth by the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 User 

Manuals, attached hereto as Appendix A , B, and F.

ii. The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs 

Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area.

The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs may be operated in both 

manual and fully autonomous flight modes with their DJI flight controllers. A complete 

description of the flight and navigational modes of the Freefly Cinestar 8, Freefly Alta, 

and DJI Inspire 1 UASs is provided at pages XX of the DJI WooKong M (which is he 
19

flight controller for the Cinestar 8) manual, and pages XX of the Freefly Alta, and 

pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto as Appendix 

A and B.

iii. The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs 

Are Designed For Automatic Return To Home Point Or Hover 

In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs do not reacquire control link 

data from the GCS, the UAs will assume that the Control Link is lost and the UAs will 

return to the home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown.

A complete description of the Failsafe Functions of the Freefly Cinestar 8, Freefly Alta, 

UAS are set forth at pages 11 of the DJI WooKong M (which is he flight controller for 

the Cinestar 8) manual, and page 65 of the Freefly Alta, and pages 12-16 and 45-50 of 

the DJI Inspire 1 User Manuals, attached hereto as Appendix A and B, and F.

iv. The Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 GCS 

And Its Operation.

A complete description of the operation and specifications of the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 GCS and flight control software is provided at pages 11

of the DJI WooKong M (which is he flight controller for the Cinestar 8) manual, and 

pages 65 of the Freefly Alta, and pages 12-16 and 45-50 of the DJI Inspire 1 User 

Manuals, attached hereto as Appendix A, B, and F.

b. Flight Operations Of Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UASs Are Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer.

VIDEOLYZERS INC AND MICHAEL REID will be the only person to act as a pilot in 

command (PIC) of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs. 

Additionally, a safety observer will assist him during flight time.

c. Flights Of Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs Will 

Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, VIDEOLYZERS INC AND MICHAEL REID proposes to 

commercially operate Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs for the 
20

special purpose of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC 

must be able to communicate verbally at all times.

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents.
21

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates 

or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

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

operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.
22

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all 

manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. PIC qualification flight hours must be logged in a manner consistent with 14 

C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under 

the terms of the exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized.
23

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.
24

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 
25

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety.

VIDEOLYZERS INC AND MICHAEL REID submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the Freefly Cinestar 8, Freefly Alta, or DJI Inspire 1 

UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Considering VIDEOLYZERS INC AND MICHAEL REID’s proposed area of 

operations, and the operating limitations set forth-above; the parallel nature of private 

pilot aeronautical knowledge requirements to those of commercial pilot requirements 

(See Exemption No. 11062); and the airmanship skills necessary to safely operate the 

Freefly Cinestar 8, Freefly Alta, or DJI Inspire 1 UAS, VIDEOLYZERS INC AND 

MICHAEL REID submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

VIDEOLYZERS INC AND MICHAEL REID’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

VIDEOLYZERS INC AND MICHAEL REID will not allow any PIC to operate the 

Freefly Cinestar 8, Freefly Alta, or DJI Inspire1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the Freefly Cinestar 

8, Freefly Alta, or DJI Inspire 1 UAS training and currency requirements, that the 

PIC is able to safely operate the Freefly Cinestar 8, Freefly Alta, or DJI Inspire 1 

UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model of UAS to be 

used for operations under the exemption). In addition to the hour requirements, the PIC 

must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes).
26

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience 

that was obtained in compliance with applicable regulations will ensure an equivalent 

level of safety during VIDEOLYZERS INC AND MICHAEL REID’s proposed 

operations. The Administrator has held that prior documented flight experience that 

was obtained in compliance with applicable regulations would ensure safe operations, 

stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model 

time may be included in the 10 hours of multi-rotor time and the 10 hours may be 

included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this 

requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. 

During training, proficiency, and experience-building flights the PIC is required 

to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, VIDEOLYZERS INC AND MICHAEL REID will ensure safe operations 

by not allowing any PIC to operate the Freefly Cinestar 8, Freefly Alta, or DJI Inspire 1 

UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Freefly Cinestar 8, Freefly Alta, 

or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety.
27

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, VIDEOLYZERS INC AND MICHAEL REID will ensure that the 

Freefly Cinestar 8, Freefly Alta, or

DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance 

with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs 

will be provided to the PIC via GPS equipment and a radio communications telemetry 

data link, which downlinks from the UA to the GCS for active monitoring of the flight 

path and altitude. This altitude information, combined with VIDEOLYZERS INC AND 

MICHAEL REID’s operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 

2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, VIDEOLYZERS INC AND 

MICHAEL REID will ensure that it will safely operate the battery powered Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UAs during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes.
28

Here, as in Exemption No. 11109, the technical specifications of the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and 

the location of the proposed operations, will ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs provide audible and visual 

warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first 

warning occurring at approximately 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will descend and land 

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety.

In seeking this exemption, VIDEOLYZERS INC AND MICHAEL REID submits that the 

equivalent level of safety with regard to the regulatory maintenance and alteration 

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because VIDEOLYZERS INC AND MICHAEL REID will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the operating documents 

(i.e., the VIDEOLYZERS INC AND MICHAEL REID Aerial Operations Manual, Monthly 

Maintenance Log, and Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 Instruction 

Manual). Furthermore, VIDEOLYZERS INC AND MICHAEL REID will document and 

maintain all maintenance records for the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 

UASs.

Since the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, VIDEOLYZERS INC AND MICHAEL REID

will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the Freefly Cinestar 8, Freefly Alta, and DJI 

Inspire 1 User Manuals are attached hereto as Appendix A and B; a copy of the Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UAS Maintenance LOG is attached hereto as 

Appendix F.
29

Likewise, the exemption sought will not adversely affect safety because 

VIDEOLYZERS INC AND MICHAEL REID will use trained technicians to 

perform maintenance, alterations or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs will be performed by trained 

technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the 

UAS are considered.

In consideration of VIDEOLYZERS INC AND MICHAEL REID’s proposed 

operating limitations, the operating documents, and the technical aspects of the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, VIDEOLYZERS INC 

AND MICHAEL REID submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), 

and

91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, VIDEOLYZERS INC AND 

MICHAEL REID requests that the FAA prescribe special conditions for the intended 

operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) 

& (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the 

limited purpose of conducting aerial video and photography over certain areas of the 

United States for compensation or hire. FMRA Section 333 sets forth the requirements 

for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, 

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 
30

appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft engine, 

or propeller because of a novel or unusual design feature of the aircraft, aircraft 

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of the Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which VIDEOLYZERS INC AND MICHAEL REID Seeks 

Exemption:

VIDEOLYZERS INC AND MICHAEL REID seeks exemption from the 

requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption 

VIDEOLYZERS INC AND MICHAEL REID Seeks:

This exemption will permit VIDEOLYZERS INC AND MICHAEL REID to 

commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United 

States.
31

• Any Additional Information, Views, Or Arguments Available To 

Support VIDEOLYZERS INC AND MICHAEL REID’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 

2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, VIDEOLYZERS INC AND 

MICHAEL REID’s request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without 

airworthiness certification.

As discussed in detail above, VIDEOLYZERS INC AND MICHAEL REID will 

operate the Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs safely in the NAS, 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.

CONCLUSION

As set forth herein, VIDEOLYZERS INC AND MICHAEL REID seeks an exemption 

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA), which will permit safe operation of the Freefly Cinestar 8, 

Freefly Alta, and DJI Inspire 1 UASs commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over 

certain areas of the United States. By granting this Petition, the FAA Administrator will 

be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing VIDEOLYZERS 

INC AND MICHAEL REID to safely, efficiently, and economically operate the Freefly 

Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, VIDEOLYZERS INC AND 

MICHAEL REID respectfully requests that the Administrator grant this Petition for an 
32

exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the 

Freefly Cinestar 8, Freefly Alta, and DJI Inspire 1 UASs commercially for the 

purpose of conducting aerial video and photography over certain areas of the United 

States.

Dated: March 6, 2015

Respectfully submitted,

VIDEOLYZERS INC AND MICHAEL REID

VIDEOLYZERS INC AND MICHAEL REID

27 Castle Harbour Drive

Port Perry, Ontario, Canada

L9L 1P4

647-262-8987
33

Appendices:

A – Freefly Alta Manual

As the manual is a very large file, please see the link at:

http://d27w8s76bjlz9v.cloudfront.net/wpcontent/uploads/2015/07/28175748/ALTA_Man

ual_RevB.pdf
34

B – DJI Inspire 1 Specifications Data Sheet:

As the manual is a very large file, please see the following link:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.

4_en.pdf
35

C – DJI Woo Kong M Flight controller

As the manual is a very large file, please see the link at:

http://download.dji-innovations.com/downloads/wkm/en/WooKongM_Quick_Start_Guide_v1.14_en.pdf
36

D –Cinestar 8 Manual

As the manual is very large, please see the link at:

http://d27w8s76bjlz9v.cloudfront.net/wpcontent/uploads/2014/07/cinestar8Manualv4.pdf
37

E – Preflight checklists

Attach camera to gimbal, ensure secure and properly aligned. 

Unfold GPS antenna, ensure locked. 

Visually inspect airframe, motors & props, wiring. 

Power on transmitter. 

Verify correct power setting. 

Validate aural start-up tones, verify configuration, set battery count-down timer to match installed battery, 

observe all switch positions, verify transmitter voltage. 

Power on camera, verify operation. 

Power up UAS by connecting inflight battery.

Validate aural start-up tones. 

Observe gimbal operation, validate pitch control via transmitter control. 

Verify LEDs on each motor arm, verify DJI LED status light operating normally. 
38

Apply power to visual monitor. 

Verify proper channel reception and adequate receiver voltage, verify video and iOSD display normal. 

For GPS operations, confirm reception of at least 6 satellites prior to take-off. 

Start motors in idle briefly, then increase above 0%, validate Home Position recorded by flight controller

via LED status light. 

Transmitter count-down timer begins when throttle increased above 0%. Continue to increase throttle until 

take-off thrust is attained.
39

F – Monthly Maintenance Log
40
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