RE: Application for exemption under section 333, Federal Aviation Administration Modernization and 

Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. 

Part 11.81, Silly Goose Media, LLC, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft for photography /

cinematography for the film, TV and internet media industries. All operations shall be conducted within and 

under the conditions and limitations outlined previously by the FAA as required by Section 333 and 

conducted in compliance with the attached operator’s manuals. 

1. Application is hereby made for exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

2. Relief sought: 

a. Silly Goose Media, LLC wishes to operate small Unmanned Aircraft Systems (sUAS) for 

commercial purposes to include (but not be limited to) photography and cinematography. This relief 

is sought because commercial use of sUAS is currently prohibited by law unless performed under 

an exemption. 

Sept 30, 2015 

SILLY GOOSE MEDIA, LLC

1308 Factory Place, unit 503

Los Angeles, CA 90013

310·776·5266

info@sillygoo.se

TO: US Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590
b. This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources: 

i. Gryphon Dynamics XQ-900V (carbon fiber, X8 coaxial multirotor frame): 

1. Total weight with maximum allowable payload: 18.1lbs (8,164g)

2. Dimensions: 

Frame width: 900mm (35.43 inches)

Maximum width with propellers: 1331mm (52.43 inches)

Height with landing gear extended: 469.9mm (18.5 inches)

3. Maximum speed: 16m/s (30kts)

4. Battery system: Dual 6 cell, 22.5 volt, 15,000mAh lithium polymer batteries, 15 

minute flight time with 2 minute reserve.

5. DJI A2 flight controller running firmware version 2.5 or later. Provides GPS, 

compass and IMU stabilized flight control complete with failsafe return to home 

operation. 

6. HD video first person view downlink for advanced flight safety providing real-time 

video from the sUAS as well as critical flight systems status and data to video 

monitor on transmitter. 

7. 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.

ii. DJI Phantom 3 quadcopter (plastic X4 multirotor frame): 

1. Total weight with maximum payload: 2.82lbs (1,280g)

2. Dimensions:

Frame width: 352mm (13.8 inches)

Maximum width with propellers: 595mm (23.4 inches)

Height (fixed landing gear): 215.9mm (8.5 inches)

3. Maximum speed: 16m/s (30kts)

4. Battery system: Single 4 cell, 15.2 volt, 4,480mAh lithium polymer battery, 20 

minute flight time with 3 minute reserve.

5. DJI advanced flight control system using GPS, compass and IMU to provide 

stabilized flight control with multiple modes of operation and failsafe return to 

home operation. 

6. HD video first person view downlink of telemetry, camera, and advanced controls.

7. 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.

iii. DJI Phantom 2 quadcopter (plastic X4 multirotor frame): 

1. Total weight with maximum payload: 2.6lbs (1,200g)

2. Dimensions:

Frame width: 350mm (13.78 inches)

Maximum width with propellers: 590mm (23.2 inches)

Height (fixed landing gear): 215.9mm (8.5 inches)

3. Maximum speed: 15m/s (29kts)

4. Battery system: Single 3 cell, 11.1 volt, 5,200mAh lithium polymer battery, 16

minute flight time with 2 minute reserve.

5. DJI NAZA M2 advanced flight control system using GPS, compass and IMU based 

technologies for stabilized flight control, incorporating multiple modes of 

stabilized flight and failsafe return to home operations.
6. DJI Lightbridge HD video first person view downlink of telemetry, camera, and 

advanced controls.

7. 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.

iv. Flight Controller and Fail-Safe systems: 

The flight controllers used in these aircraft are all provided by DJI and all provide the 

following capabilities:

a. GPS Attitude Control: The flight controller incorporates GPS technology to support 

both attitude and position hold such that the sUAS will not deviate or move except 

under command of the pilot allowing for a greater level of safe operational control. 

b. Attitude Control: The flight controller supports the ability to maintain attitudinal 

control whereby the sUAS maintains the optimal orientation for stability and control. 

Attitudinal control can be selected when GPS positioning is less than optimal. 

c. Return-to-Home (RTH): Should the sUAS lose radio contact with the pilot in 

command or should the pilot in command elect to for safety reasons, the sUAS may

enter a failsafe mode called Return to Home. In this mode, the sUAS will ascend to a 

predetermined height set by the operator if not already at or above that height. It will 

then use GPS positioning to navigate it’s way back to the take off point (or another 

point set by the pilot). It will then descend and land. The pilot in command may elect 

to interrupt the RTH function at any point once he has regained radio control. 

v. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents. Filming in manned 

aircraft at close proximity to populated areas and/or near power lines, suspension cables, 

buildings, etc. to obtain aerial images for film, TV and internet poses a high risk to both 

operator and public. Aerial imaging achieved with sUAS can reduce this risk substantially 

when conducted safely and responsibly.

ii. Reduces the cost of obtaining aerial imagery which benefits consumers and the economy. 

Aerial imaging with manned aircraft is both disruptive and costly. Unmanned sUAS operation 

can significantly reduce the cost and overheads associated with obtaining aerial images and 

makes them more accessible to content creators and entertainment companies.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 

45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair 

and maintenance work will be conducted or approved by qualified personnel such as those 

authorized by Silly Goose Media, LLC (or equivalent), and will require a test flight after such work. 

Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. 

c. All operations will be conducted in accordance with valid Certificates of Authorization. 

d. All flight operations will comply with the following: 

i. The manufacturers’ user manuals. 

ii. Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM), 

which include lost communication and other emergency and safety procedures. 
iii. Conducted in VMC conditions during daylight hours. 

iv. PIC will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and safety risk assessments 

will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Flight will not intrude into Class B, C or D airspace, or published approach, SID or STAR, 

or take place within 5 nautical miles of an airport. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the 

ground without their prior permission. 

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. 

xi. Not to exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever 

occurs first. 

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. Any applicable local FSDO requirements. 

xiv. All other applicable regulations concerned with the operation of aircraft. 

e. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined 

and tested lost link procedures. 

Please advise of any additional information or changes that may be required. 

Sincerely, 

__________________________________

Ian Wood

Silly Goose Media, LLC