Limitless Media Productions, LLC

Section 333 Exemption Request 1

U.S. Department of Transportation,

Docket Management System,

1200 New Jersey Avenue SE,

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Limitless Media Productions, LLC a North Carolina limited liability company (“Limitless Media 

Productions”), hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS). 

We have enclosed the sUAS manufacturer's operations flight, instruction manual, and 

maintenance manuals and any other requirements established by the FAA pursuant to Section 

333 of the Reform Act.

The requested exemption would permit Limitless Media Productions to pursue its commercial 

interests in providing services to clients using small advanced sUAS in rural or sparsely 

populated North Carolina, with particular focus on the following commercial areas:

• Oil and Gas Infrastructure Monitoring and Inspection Services

• Mining Inspections

• Aerial Surveying

• Industrial Facilities Inspections

• Conservation Reviews

• General Video and Photography assignments

• Inspection of Power and Wind Towers

In addition to the waiver authority provided in Section 333 of the Modernization Act, the FAA 

may grant an exemption under 49 U.S.C. Section 44701(f) if it has determined that such an

exemption is in the public interest.

Granting an Exemption is in the Public Interest.

Currently, various businesses must hire traditional manned aircraft in order to obtain aerial views 

of their property for inspection and advertising purposes. These manned aircraft pose significant 

risk to aircraft operators, nearby property, and persons in the area. The use of sUAS for general 

asset evaluation would reduce the risks to personnel and property by allowing for remote aerial 

review. Further, the use of sUAS have the potential to improve efficiency, resulting in faster and 

safer delivery of asset evaluation, all while significantly reducing the risk of human and property

loss. 

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)
Limitless Media Productions, LLC

Section 333 Exemption Request 2

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.401 – 91.417

An exemption would allow Limitless Media Productions to broadly evaluate assets and 

operations with sUAS, resulting in a safer and more efficient inspection and monitoring regime 

in the resource industries. Accordingly, the grant of an exemption is consistent with Congress’ 

intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 

(Modernization Act), that safe systems be permitted in the national airspace prior to the issuance 

of final regulations governing general use of these systems.

This exemption would permit commercial operation by Limitless Media Productions, which uses 

DJI Phantom 3 Professional sUAS’, to conduct general asset inspections. Limitless Media 

Productions’ operation under the exemption will be subject to strict operating requirements and 

conditions to ensure an equivalent level of safety to currently authorized operations using 

manned aircraft and under conditions as maybe modified by the FAA as required by Section 333.

Limitless Media Productions states that all sUAS flights will occur over private or controlled 

access property, will do so with the property owner’s consent and knowledge, and only people 

who have consented or agreed will be in the area where flights will take place.

Furthermore the petitioner will only operate its sUAS in line-of-sight (VLOS) of a pilot and/or 

observer and will operate at sites in North Carolina that are ‘sufficient distance’ from populated 

areas within the sterile area described in the Limitless Media Productions’ Flight Operations

Operating Manual. Such operations will ensure that the sUAS will “not create a hazard to users 

of the national airspace system or the public.”

Additionally, Limitless Media Productions’ crew will consist of a sUAS pilot who will hold a

FAA commercial pilot certificate with a first class medical certificate or a sports pilot license 

with a Class III Medical Certificate, plus a Visual Observer (VO). 

In keeping with previous exemptions granted, we will ensure that operations will not occur 

within 5 miles of an airport. The sUAS operated by Limitless Media Productions all weigh less 

than 25 pounds, including payload (i.e. sensors, camera, lens, and stabilized gimbal), and operate 

at speeds below 50knots, and will not be operated at altitudes that exceed 500 feet AGL.

Given the small size of the sUAS and the restricted sterile environment within which it will

operate, Limitless Media Productions’ operations adhere to the Reform Act’s safety 

requirements. The fact the pilot holds an FAA Private Pilot license demonstrates Limitless Media 
Limitless Media Productions, LLC

Section 333 Exemption Request 3

Productions’ high regard for safe operations with an understanding of FARs, pre-flight 

inspections, knowledge of operations and differences in airspace classifications, maintenance and 

repair, as well as being trained to high safety standards. 

We respectively request exemption under Section 333 to enable Limitless Media Productions to 

operate efficient, limited, low-risk commercial sUAS operations for the activities stated, 

respecting at all times the space and privacy of citizens and property while keeping airspace safe.

Sincerely,

R. Grant Allison

Limitless Media Productions, LLC

Promoter

Raleigh, NC 27609

(704) 614-0783

limitlessmediaproductionsllc@gmail.com