108	S.	12th	Street	!	Tampa,	Florida	33602	!	P:	(813)	229-1212	!	F:	(813)	229-6333	!	www.wearespectrum.tv

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir/Madam: 

This petition is being submitted on our own behalf without legal counsel or consulting 

services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”), and 14 C.F.R. Part 11, Spectrum Field Productions LLC

(“Spectrum”), a Florida based limited liability company operating a Small Unmanned 

Aircraft System (“sUAS”), with our employee Nicholas Righi as the PIC, equipped to 

conduct aerial photography, videography, and survey for various industries, hereby 

applies for an exemption from the Federal Aviation Regulations (“FARs”) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 

333. 

The requested exemption would permit Spectrum to pursue its commercial interests in 

providing services to consumers’ interested aerial data capture using a small advanced 

sUAS in the following areas: 

• Agricultural Surveying 

• Aerial video/photography or providing live video feed 

• Closed Set Film Cinematography 

• Real Estate Photography 

• Product Demonstrations 

• Research and Development 

Spectrum states that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner's prior consent and knowledge and that only 

people who have consented or otherwise have agreed to be in the area where 

photography and videography will take place will be captured. 

Spectrum understands the proper roles of an observer, communication procedures, 

proper visual scan techniques, operations at non-towered airports, and appropriate 

sections of the Aeronautical Information Manual. 

Nicholas Righi has flown small multi-rotors for over three years with over 100 hours of 

flight time.
Contact Information:

Company: Spectrum Field Productions LLC

Name: Nicholas Righi

Address: 108 S 12th st Tampa, Fl 33602

Email: Nick@wearespectrum.tv

Office: 8132291212

Cell: 8132208084

Spectrum has instilled safety protocols and controls to avoid and prevent public hazard, 

as well as manned aircraft hazards/catastrophe. This will act to further safety protocols 

exclusive to lightweight UAS's specific to video and photography usage as Spectrum will 

record flight data and other information gained through permitted flight operations to 

share with the FAA through any required FAA reports to assist with future protocol and 

safety regulation. This data can be logged with the DJI Pilot app.

Regulations from which the exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)

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

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. 91.215

14 C.F.R. (91.401 - 91.417) 

Unmanned Aircraft System 

We are petitioning for exemption to enable Spectrum to operate a DJI Phantom 2 multirotor equipped with a three-axis gimbaled camera, and a DJI Inspire 1 multi-rotor 

equipped with a three-axis gimbaled camera. These sUAS all weigh less than 25 lbs., 

have a built-in capability to limit the height it flies above the ground, to limit the radius of

the distance it flies from the operator and to exclude it from Class B, C and D airspace 

including a no fly zone feature. These sUAS named above operate in the 2.4 – 5.8 GHz 

frequency range which complies with FCC regulations. Each system also has the failsafe 

function of the autopilot system, which means when the communication between the 

Main Controller and the transmitter is lost; the system will automatically trigger Return to 

Home and will land safely. 

The above specifications meet standards listed below, some derived in accordance with 

the Model Aircraft Operating Standards: 

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer 

and will operate at sites that are a “sufficient distance” from populated areas 

within the sterile area described in the operators manual. Such operations will 
insure that the sUAS will "not create a hazard to users of the national airspace 

system or the public." 

• When flying sUAS within 3 miles of an airport, airport operators will be notified

and the operator will give the right of way to avoid flying in the proximity of fullscale aircraft. 

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to 

the 60 minute limit. 

• The sUAS will be programmed so that it will not be operated at an altitude of no 

more than 400 feet AGL, and not more than 200 feet above an elevated platform 

from which filming is planned. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal). 

• The sUAS will operate at speeds of no more than 55 knots. 

• Given the small size of the sUAS and the restricted sterile environment within 

which they will operate, our sUAS operations adhere to the Reform Act's safety 

requirements. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Spectrum requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAS System: 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned 

Aerial Systems, we request an experimental certificate be issued for the DJI Phantom 2,

and the DJI Inspire 1 under either or both of the following provisions: 

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new

aircraft equipment, new aircraft installations, new aircraft operating techniques, or

new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to 

show compliance with the airworthiness regulations including flights to show compliance 

for issuance of type and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function and reliability 

requirements of the regulations. Since the experimental certificate can be used for 

commercial purposes such as market surveys, sales demonstrations, and customer 

crew training, we would expect that an experimental certificate would permit our 

commercial purpose as well. The aircraft will not carry persons or property, will not carry 
fuel, and will only fly under strict operational requirements. Combined with the UA's light 

weight, being constructed primarily of foam, carbon fiber, and/or plastic, we propose that 

the UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, 

Subpart H, and the requirement for an airworthiness certificate in general, citing the 

equivalent level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The sUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation. Additionally, we feel that the permanent placard discussed 

in the previous paragraph will provide the aircraft's registration information at the ground 

station. Finally, we will display at the ground station a high contrast flag or banner that 

contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or 

greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point 

of origin. 

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial

operations. Further, while helpful, a pilot license will not ensure remote control piloting 

skills. The risks attended to the operation of my UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing 

Spectrum to operate my UAS to meet and exceed current safety levels in relation to 14 

C.F.R. §61.113 (a) &(b).

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. We assume that the intent of this requirement is 

to ensure that flight manual information is available to the aircrew while operating the 

aircraft. We request an exemption to this requirement since the aircraft is not only too 

small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 
mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planned has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the small size of 

the UAS, the hazard to persons, vehicles and structures is minimal compared to manned 

aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 

600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the sUAS on-board computer to the display screen 

held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAS are battery 

operated and the maximum duration of flight from a single battery charge is 12-45 

(depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly 

more than 1/2 NM from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We request an 

exemption to the word "fuel" and ask for an equivalent interpretation with the word 

"energy". We also request exemption from the 30 min reserve and ask that our reserve 

will be to fly the mission to the point of intended landing and have at least a 20% battery 

reserve after that. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." With our largest 

vehicle, the DJI Inspire 1, at a maximum gross weight of 7 pounds, the sUAS is too small 

to carry documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent of 

91.203, we propose that documents deemed appropriate for this aircraft by the FAA will 

be co- located with the crew at the ground control station and available for inspection 

upon request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via 

placard containing the following information plus the word "EXPERIMENTAL" to satisfy 

the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 
authorized under 43.7" after maintenance and inspection. It is our intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition, conduct detailed inspections after every two 

hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed in 

accordance with 91.417. We feel that due to the size, construction, and simplicity of the 

aircraft, the PIC can ensure an equivalent level of safety. 

Re: Exemption Request Section 333 of the FAA Reform Act 

Thank you for the opportunity to give examples as to why granting Spectrum the 

requested exemption would be in the public interest, and how it would benefit the public 

as a whole. Please find that following examples supporting this exemption. 

1. UAS use as an alternative to large, manned aircraft using combustible fuel in Cinema 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels to both the pilots aboard and people 

below, thereby enhancing safety and drastically diminishing the likelihood of death or 

serious bodily injury. The small weight and minimal payload allows for high quality aerial 

video at safety levels before unseen. 

2. Public Good: Closed Set Cinematography 

Spectrum can offer the same aerial videography a production is requesting without any 

of the danger associated with a traditional full sized manned helicopter using 

combustible fuel when flying over a set. GPS stabilized stationary angles and low 

altitudes, predictable flight paths with full coordination between people on the ground 

without need for complicated communication systems, and the ability to land safely in a 

comparably smaller area to a full sized aircraft all increase safety and public good. The 

costs of the production are drastically lowered and safety is raised. High quality aerial 

cinematography becomes accessible to smaller productions, facilitating market growth 

and public job creation. 

3. UAS use in Aerial Photography 

UAS use in photography creates dramatic versatility never before possible. The impact 

of this versatility creates immediate value to small and large businesses, charity 

organizations, and private citizens. Small businesses would never have access to the 

production value of an aerial photo without great expense, usually reserved for larger 

corporations. Having access to this for promotion needs is a large benefit to businesses. 
We respectfully request exemption under Section 333 to enable Spectrum to operate 

safe, low- risk commercial sUAS operations for the activities stated. Spectrum at all 

times will respect the space and privacy of citizens and property whilst keeping our skies 

safe. 

Sincerely,

NICK RIGHI 

Spectrum | Director of Photography

813.229.1212 x243

nick@wearespectrum.tv

wearespectrum.tv