In-Reflection LLC/Studio | 58 Hawaii Drive, Aliso Viejo, CA 92656

Re: Section 333 Exemption Petition

January 8, 2016

U.S. Department of Transportation, 

Docket Management Facility 

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., 

Washington, DC 20590

Dear Sir or Madam, 

I, Garland West, on behalf of my company, In-Reflection LLC/Studio, am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R.11. I would like to 

request that In-Reflection LLC., a Video/Photography Production/Marketing Company, and owner/operator of 

two small unmanned aircrafts, be exempted from the Federal Aviation Regulations (“FAR”) listed below so that 

I, Garland West, may safely operate these two unmanned aircraft systems (“UAS”) commercially conducting 

video marketing and photography within the construction, real estate, and non-profits industry in airspace 

regulated by the Federal Aviation Administration (“FAA”). 

Applicant: 

Garland West

In-Reflection LLC/Studio

58 Hawaii Drive, Aliso Viejo, CA 92677

949-933-7327 

garland@inreflectionstudio.com

Regulations from Which the Exemption is Requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c)

14 CFR 91.121 

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b) 
Extent of Relief and Why: 

14 CFR Part 21 subpart H 

The two UAS to be operated carry neither pilot nor passenger and carry no explosive materials or

flammable liquids. Given the size, weight, speed, and limited and controlled operating area associated with the 

aircraft to be utilized, exception is requested. In the restricted environment and under the conditions proposed,

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without said restrictions. 

14 CFR 45.23 (b) 

Due to the size of the two UAS, there is no cockpit, cabin, or pilot station on which to market certain words or 

phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to be 

smaller than required minimum. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA

regulatory standard will exist for determining airworthiness. Given the size of the aircrafts for maintenance and 

use of safety checklist prior to each flight an equivalent level of safety will be

provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the two UAS have no ability to carry a flight manual on the aircraft. There is 

no room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will be 

maintained by keeping the flight manual at ground control point where the pilot will have immediate access to 

it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft, an exemption will be needed. Preflight 

procedures, as described in the attachment “DJI Pilot Training Guide” (See Appendix D). An equivalent level of 

safety will be provided as set forth in the Manual. The operator will take all actions including reviewing weather, 

power source requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through 

the use of a control box that communicates with the aircraft via radio communications. The equivalent level of 

safety is provided because neither a pilot nor passenger will be carried in the aircraft, and due to the speed 

and size of the aircraft. 

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my two UAS do not 

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS have a GPS altitude read out rather than a barometric altimeter. An equivalent level of safety is 

achieved by the operator receiving live flight data monitoring and confirming current altitude along with altitude 

of launch site shown on GPS altitude indicator. 
14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the two UAS have no ability to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately such 

documents. An equivalent level of safety will be achieved by keeping these documents; to the extent they are 

applicable to the UAS, at the ground control point where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificate, these sections do not apply to this 

applicant. As a safety precaution, the operator will perform preflight inspections and ensure the two UAS are in 

working condition before initiating each flight. 

These are in accordance with FAA Publication: Public Guidance for Petitions for Exemption Filed under 

Section 333 (Rev. 9/25/14). The petitioner submits this application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent the petitioner from 

contemplated Commercial Videographer encompassing Aerial Video Marketing, Cinematography, Real Estate, 

Academic and other Video Production related flight operations within the national airspace system (NAS). 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. The petitioner’s two ultra-light weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of Petitioners two 

ultra lightweight UAS is expressly contemplated by the Reform Act. 

I, Garland West, have five years of UAS piloting experience as a hobbyist, without incident. I also have 

videography experience and a vested interest in the industry. I can provide direct experience and valuable 

information to develop requirements and protocols for formal regulation that can be administered regarding 

various applications related to UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall capabilities of the two UAS; 

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 reflects in favor of an exemption. Both of 

my UASs utilize four (4) counter-rotating propellers for balance, control and stability; both UAS are equipped 

with GPS and auto return safety technology; both weigh less than fifteen (15) pounds (far below the max. 55-

pound limit); and both include a camera with gimbal. I always fly line of sight below 250 feet away from 

populated areas, airports, hospitals, and heliports. Prior to and during every flight, strict pre-flight and in-flight 

protocols are followed. (See Appendix C). 

Safety: 

I, Garland West, consider safety critical with each flight. Both my DJI Phantom 3 Prof. and DJI Phantom 2 V

Plus are designed to hover in place via GPS and operate per in flight protocol in less than a 13-knot (15 mph) 

wind. Built-in safety systems include a GPS mode that allows the two UAS to hover in place when radio 

controls are released. With three modes to choose from, we utilize the Safe Mode for aerial 

videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. 

When pilot communication is lost, the two UAS is designed to slowly descend to point of take-off. I am

constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and 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. Flights generally last between ten (10) to fifteen (15) minutes, 

with an altitude under three hundred (300) feet. Altitude and distance limits are set within the firmware (see 

Appendix A and B). Also, programmed into the firmware are early battery warnings starting at 30% battery 

power remaining. Typically, I land the two UAV at no lower than 38% battery remaining for further safety 

precautions. 
How In-Reflection, LLC’s Request Will Benefit the Public as a Whole: 

Recognizing that the UAV industry and technology is an on going consideration for the FAA with regard to 

public safety as well as the safety of our National Airspace, I Garland West, owner and operator of multiple

UAV, consider safety as the highest priority. In order to ease the tension of the unknown, In-Reflection, LLC 

will happily educates and trains both public and new UAV users on the safety, regulations, uses, applications, 

and do’s and don’ts. There is limited manpower and as the industry expands, it is companies like In-Reflection, 

LLC and pilots like myself who will assist the FAA in a safely integrating UAV into the sky. 

On coastal building projects, In-Reflection, LLC will survey the property to demonstrate any environmental 

impact to the Coastal Commission. This is done when the architect and In-Reflection develop the flight pattern 

at various altitudes over land and sea to develop the property profile. This saves the environment by using a 

batter-powered UAV instead of a gas or diesel-powered helicopter, plane or boat to accomplish the same 

purpose. This decreased need for manned helicopters, planes or boats to capture aerial videography reduces

the risk of life in the air and on the ground. In addition the mentioned quadcopters produce less noise and air 

pollution than conventional methods of aerial videography. 

In-Reflection will work with non-profit developers and builders to assist in building homeless shelters by 

creating structural CAD overlay on reconstructed homes based on aerial shot at different angles. By flying 

over taking pictures of existing structures, we are able to create an overlay of what the new home will look like 

to raise money for the shelter.

In-Reflection will be able to capture footage that would otherwise be impossible or too costly to accomplish. 

This cost savings and new perspective will open up opportunities to learn more about our communities and 

businesses in a way we could have never imagined. 

Summary: 

For the reasons stated below I, Garland West, respectfully request the grant of an Exemption allowing me to 

operate ultra-light weight, two remote controlled UAS for the purpose of producing dynamic videography and 

cinematography promoting economic growth for the local community while educating the public on the correct 

and safe way of UAS integration into the national airspace. 

Lastly, the FAA has issued grants of exemption in circumstances similar in all material respects to those 

presented in my petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see 

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA 

found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by 

the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater

proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS 

operation enabled by this exemption is in the public interest. 

As described herein I, Garland West, am experienced in flying quadcopters and am an owner of an established

and insured marketing company (In-Reflection,LLC) based out of Aliso Viejo, California. In-Reflection has been 

in business for eight years providing video services to an array of clients. I currently own and fly a DJI Phantom 

3 Professional Quadcopter and a DJI Phantom 2 V Plus Quadcopter (see appendix A for DJI Phantom 3 

Professional and Appendix B for Phantom 2 V plus) with over 200 hours combined flight time on the listed 

UAV’s. I, Garland West, submit this 333 Exemption with intent and desire to add and utilize this technology for 

the purpose of continuing to produce dynamic content and accommodate the request of our existing and future 

client base seeking to utilize this revolutionary technology and the unbelievable perspective this technology is 

able to safely capture, following exemption and approval by the FAA. I have flown multi-rotors for over five (5) 

years without incident. 

Committed to safety with each flight, my exemption request would permit operation of ultra lightweight, UAS for 

commercial use in tightly controlled and limited airspace. Pre-determined, I would operate only in areas away 

from general public, airports, heliports and vehicular. Furthermore, based on my recreational filming on the 

coast, I believe I am in a unique position to assist the FAA in developing operational and safety protocols for 

lightweight UAS as they are integrated into the National Airspace. Currently this seems to be a major issue as 
the drone industry explodes and the uneducated take to the skies. I, Garland West, have personally 

implemented safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft 

hazards and catastrophe. This will act to further safety protocols exclusive to lightweight UAS. 

Granting my request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and 

authority to integrate UAS into the National airspace system, and to “...establish requirements for the safe 

operation of such aircraft systems [UAS] in the national airspace system” under Section 333(c) of the Reform 

Act specific to the use of UAS for Cinematography/Photo purposes. Further, I, Garland West, will conduct my 

operations in compliance with the protocols described herein or as otherwise established by the FAA. 

As set forth herein, Garland West, owner of In-Reflection, LLC 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 DJI Phantom 3 Professional and a DJI Phantom 2 V Plus UAS 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 Garland West, owner of In-Reflection, LLC to safely, efficiently, and economically operate the DJI 

Phantom 3 Professional and a DJI Phantom 2 V Plus UAS commercially within the NAS. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, 

Section 333, Garland West owner of In-Reflection, LLC seeks Exemption Request Section 333 of the FAA 

Reform Act of the Federal Aviation Regulations from 14 CFR Part 21, 14 C.F.R. 91.109, 14 CFR 91.405 (a), 14 

C.F.R. 45.23(b), 14 C.F. R. 91.119, 14 CFR 407 (a) (1), 14 CFR 61.113 (a) & (b), 14 C.F.R. 91.121, 14 CFR 

409 (a) (2), 14 C.F.R. 91.7 (a), 14 CFR 91.151 (a), 14 CFR 417 (a) & (b), 14 CFR 91.9 (b) (2), 14 CFR 91.203 

(a) & (b), 14 C.F.R. 91.103 

Dated: January 8, 2016

Respectfully submitted, 

Garland West

In-Reflection,LLC/Studio.

58 Hawaii Drive

Aliso Viejo, CA

949-933-7327

garland@inreflectionstudio.com 
APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

GARLAND WEST OF IN-REFLECTION LLC/STUDIO only utilizes safe and reliable UASs. DJI is an 

industry leader in small UAS production. DJI UAS’s are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit 

flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance.

In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor 

(smart phone/tablet devices)

DJI Phantom 3

1.1 Aircraft

1.1.1 Supported Battery – DJI 6000AH LiPo Battery

1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.4 Max Yaw Angular Velocity - 200/s

1.1.5 Max Tilt Angel - 35 1.1.1.6 Max Ascent Speed – 6m/s

1.1.6 Max Descent Speed – 2m/s

1.1.7 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.2 Gimbal

1.2.1Working Current – Static: 750mA; Dynamic: 900mA

1.2.2 Control Accuracy - ±0.03

1.2.3 Controllable Range – Pitch: -90 - 0

1.2.4 Maximum Angular Speed – Pitch: 90/s

1.3 Camera

1.3.1Operating Temperature Range - 32F - 104F (0C - 40C)

1.3.2 Sensor Size – 1/2.3”

1.3.3 Effective Pixels – 14M

1.3.4 Resolution – 4384x3288

1.3.5 HD Video Recording – 1080p30 & 720p

1.3.6 Recording Field of View - 110/85

Full specifications can be found at:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf
APPENDIX – B

DJI PHANTOM 2 VISION PLUS TECHNICAL SPECIFICATIONS

GARLAND WEST OF IN-REFLECTION LLC/STUDIO only utilizes safe and reliable UASs. DJI is an 

industry leader in small UAS production. DJI UAS’s are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit 

flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance.

In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor 

(smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

Full specifications can be found at:

http://download.dji-innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.1.1_en.pdf
APPENDIX (C) 

PRE AND IN FLIGHT PROTOCOLS

Protocols and Controls

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.

Check weather forecasts for wind advisory or other conditions that my impact flight.

Consult five (5) mile radius map for airport vicinity.

• 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:

• Vicinity of public safety helipads/heliports

• Vicinity of medical helipads/heliports

• Vicinity of light poles

• Vicinity or utility wires

• Vicinity of trees

• Flocks of birds that may cause interference and potential flight impact

• Vicinity of any elevated obstructions that may pose potential flight hazard

• Vicinity of roadways with moderate to heavy traffic that can be distracted

• Public gatherings that may attract viewers

• Optional point of control for best visual site of UAS while in flight takeoff and landing

• Inspect area for best and safest point of takeoff and landing

• 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 minim al elevation sufficient to acquire desired results

• Remain prepared for emergency landing at all times

• Pay attention to flight time

• If possible set a timer as a safety alert

• Land UAS and shut down propulsion immediately following landing Protocols and Controls
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

• Manned aircraft is heard or seen in vicinity of flight

• There is a public gathering within established safety boundary wanting to observe flight

• Pilot is being distracted from focusing on flight and safety

• Sudden change in weather (wind bursts)

• Sudden increase in vehicular traffic in vicinity of flight

• Birds enter into proximity of flight

• Any sudden unsafe event that can cause collision, distraction or interruption of control
APPENDIX (D) 

SAFETY AND FLIGHT MANUAL

Aerial Video/Photography