APPLICATION/PETITION FOR EXEMPTION (Drone “UAV” Use) 

Manager of Risk and Crowd Services

SFX Entertainment

430 Park Ave

New York, NY 

sdennison@sfxii.com

Tel; 480-707-3798

STATED SECTION(S) FOR RELIEF SOUGHT 

COMES NOW, SFX Entertainment, Inc. herein after referred to as SFX, and does hereby submit and 

request exemptions to FAA Rules for drone (UAV) usage, and seeks an exemption Filed under Section 

333 to grant relief from and an airworthiness Certificate under the FAA Modernization and Reform Act 

of 2012, Public Law 112-95 FEB 14,2012, Section 333. SFX is a domestic public company that specializes 

in the production of large Music Festivals around the United States. At all times, SFX carries insurance, is 

fully legal in all Stats and has NEVER operated a UAV at any time, prior to this application being filed. 

Our use of the DJI 900 is less than 3.3kg and does not fly over 35 mph and does not operate in proximity 

to airports and populated areas, and operation is within a visual line of sight does not create a hazard to 

users in the national airspace system or the public or pose a threat to national security.

Exemption under the Requirements of 14CFR 11.81

SFX will conduct UAV operations safely to minimize risk to the NAS or to persons and property on the 

ground. SFX will use its UAV to conduct monitoring of traffic flow and parking lots in order to assist 

State and Local Law Enforcement agencies in traffic management at our outdoor music festivals. The 

cost incurred by obtaining a helicopter is excessive and the monitoring of traffic using a UAV is an 

economic advantage to all parties concerned. In fact many local law enforcement agencies do not have 

access to helicopter for this purpose.

We have included in this submission a copy of the DJI 900 a commercially available UAV that has been 

used extensively in the United States with an excellent safety record.

SFX has an ongoing relationship with FAA headquarter (Mr. Brian Thoorp brian.thoorp@faa.gov) for 

limiting overflights at our concert venue and also DHS (JONATHAN D. RICHESON, Security Specialist 

Commercial and Government Facilities Section, Sector Outreach and Programs Division Department of 

Homeland Security.

Prior to any flight a complete pre-flight is conducted, weekly operational inspections and an annual 

inspection by an authorized DJI service center to insure that all operational components are in proper 

factory specifications. (See Attached manual)

The Radio Frequency spectrum that is used for control and its associated equipment is in the 2.4 giga 

hertz range and complies with the Federal Communications Commission requirements.
Pilot in Command

The UAV for SFX will only be operated by Mr. Scott Dennison the Manager of Risk and Crowd Services. 

Mr. Dennison is a licensed commercial pilot with instrument and multi-engine rating with over 7000 

hours of flight time in a variety of aircraft (Certificate number 579623050). Mr. Dennison also has a BS 

degree in Aviation Technology from Purdue University. In addition Mr. Dennison is also a former 

Special Agent for FAA and Federal Air Marshall. Mr. Dennison also is actively involved with many 

Federal Agencies to include DHS.

Mr. Dennison has taken a variety of significant courses offered by DJI the manufacturer of the UAV on its 

operation and safety requirements.

Mr. Dennison knows the safety threat these vehicles can pose to air traffic, the general public and 

others, and as such, since he has a working, and real world knowledge, his operation of a UAV is far 

superior than that of an operator that merely buys a UAV and then operates it outside the confines and 

guidelines/regulations of the FAA. 

Proposed Operations:

SFX has 5 major outdoor festivals a year located in remote communities. The Manager of Risk works 

closely with Federal, State and Local Law Enforcement to insure a safe environment for our employees, 

patrons and the local community. In this effort the proper management of traffic into and out of the 

event is of major concern to law enforcement and the local community. 

In order to properly manage traffic operations information must be passed to State and Local law 

enforcement on the flow of traffic into and out of the event along with the current status of parking lot 

capacities. Due to the limited number of police officers available to monitor traffic operations and the 

excessive cost of renting a helicopter the UAV offers immediate information to all involved at an 

economical cost.

The UAV will be operated at altitudes not to exceed 300 feet and a forward speed of less than 25 mph. 

Minimum flight visibly will be set at 3 miles. The UAV is not intended to be flow over persons but only 

to monitor traffic operations. If winds exceed 25 mph the UAV will not be used. Safety measures in 

place for the UAV are contained in the operations manual of the DJI900. In addition the DJI900 used by 

SFX is equipped with a deployable parachute that can be remotely operated. All flights by the SFX UAV 

will be line of sight with an observer and the pilot, during daylight conditions, inside Class G 

(uncontrolled) airspace and more than five miles from any airport or other location with aviation 

activities. 
Operational Area

The UAV use is intended solely for the footprint of the venue for each music event on a conditional use 

permit granted by the county or city of the event. Prior to any operational use a complete risk 

assessment is done to determine any obstructions to the proposed flight paths that would be involved. 

The UAV will not be operated within 5 miles of any airport. 

Visual line of site will be accomplished by the Pilot and his observer watching the aircraft at all times. 

Information is relayed to local law enforcement officials via 2 way radio. In addition SFX operates with 

the cooperation of Federal, State and Local Law Enforcement officials and Incident Command Post (ICP). 

All flight operations are cleared with the ICP prior to departure and prior to landing. This is in 

accordance with Section 333 (b)(1)

Pre Flight Safety Risk Assessment:

A pre-flight a safety risk assessment is done in accordance with 14CFR 91.7(b). This information is 

contained in the DJ900 operations manual. In addition to this SF Risk Department conducts a total 

assessment of all flight paths, take off locations and landing zones. The SFX risk Department has 

meteorologist on site at all times to insure the weather conditions are proper for the safe UAV flight 

operations. No operation of the UAV can occur till such time as the on-site meteorologist has approved 

the flight based on local conditions. , shall at all times, and as a minimum, observe all applicable 

regulations of 14 CFR parts 61 and 91. This document is intended to identify alternate methods of 

compliance with the regulations when evaluating proposed UAS operations. In this case, the applicant 

himself, that was in fact, is an accomplished pilot and former FAA Official, the applicant understands and 

has working knowledge of the rules of flight, air traffic patterns, safety standards, aeronautics, which 

SFX would argue is way beyond that of the typical and relevant average operator now existing and 

making use of an UAV. 

SUMMARY 

WHEREFORE, the applicant, SFX (Scott Dennison), respectfully requests a (24) month exemption to 

lawfully, within the stated regulations of the FAA and others, and as stated, operate a UAV for the sole 

purpose of traffic management for music festivals in support of State and Local Law Enforcement. 

FURTHER, it is stated and affirmed here, that SFX (Sean Murphy) has made application for the required 

COA.