August 20, 2015

Exemption No. 12551

Regulatory Docket No. FAA–2015–1293

Mr. Larry L. Letzer Jr.

Partner

Camera Artistry Photography

2908 Oak Hill Drive

Copperas Cove, TX 76522

Dear Mr. Letzer:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 5, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Camera Artistry Photography (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography and videography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+ and the DJI Phantom 3 

Professional.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
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provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your 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.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Camera Artistry Photography is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Camera Artistry Photography is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ and the DJI Phantom 3 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 5, 2014

United States Department of Transportation Docket Management System 1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam: I am writing pursuant to the FAA Modernization and Reform Act of 20121 (the 

“Reform Act”) and the procedures contained in 14 C.F.R. 11, to request that Camera Artistry 

Photography an owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (“FARs”) listed below so that Camera Artistry Photography may operate its small 

unmanned aircraft / lightweight unmanned aircraft systems (“UAS”) commercially in airspace 

regulated by the Federal Aviation Administration (“FAA”). As identified and described herein, Larry L. 

Letzer Sr. and Larry L. Letzer Jr. and their company Camera Artistry Photography, are experienced, 

recognized veterans in the photography graphic design and website development industry. Larry Sr. 

and his company have been providing quality services to their clients since 1974. Mr. Letzer Jr. has 

also been an avid Radio Controlled model builder and operator for over 15 years. Mr. Letzer Sr. holds 

a FAA Commercial certificate and is Instrument qualified. They are looking to add a valuable service to 

his clients through Camera Artistry Photograph through the use of a small, lightweight UAS as several 

of his clients have requested this type of service. Primary uses will be low altitude aerial photography 

for use on client websites and print pieces and video for use on client websites. Larry Jr. has operated 

his current UAS on several occasions non-commercially without incident. The UAS utilizes battery 

power, not combustible fuels. Flight time ranges between 5 and twenty minutes. The UAS has GPS 

functionality to hover in place as well as a return to home function in case of loss of contact with the 

radio. It has an audible and visual warning system and will start to descend slowly if battery power 

reaches 25%. The failsafe software will disable the UAS from taking off and also limit the UAS systems 

from operating within specific GPS preset no-fly zones. Camera Artistry Photography exemption 

request would permit its operation of lightweight, unmanned (piloted by remote control) and 

comparatively inexpensive UASs in tightly controlled and limited airspace. Currently, similar 

lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. It is only logical to allow Larry L. Letzer Jr. , an 

experienced remote control pilot, to operate similar lightweight UASs. This will act to further safety 

protocols specific to lightweight UASs as Camera Artistry Photography researches flight data and 

other information gained through permitted flight operations. Granting this request comports with 

the Secretary of Transportation’s (FAA Administrator’s) responsibilities to not only integrate UASs into 

the national airspace system, but to “...establish requirements for the safe operation of such aircraft 

systems [UASs] in the national airspace system” under Section 333(c) of the Reform Act. Further, 

Camera Artistry Photography will conduct its operations in compliance with the protocols described 

herein or as otherwise established by the FAA. 

For the reasons stated below, Camera Artistry Photography respectfully requests the grant of an 

exemption allowing it to operate lightweight, remote controlled UAS’s. 1. Contact Information: Larry

L. Letzer Jr. and Camera Artistry Photography 2908 Oak Hill Drive Copperas Cove, Texas 76522. email: studio@hot.rr.com 2. The Specific Sections of Title 14 of the Code of Federal Regulations From 

Which We Request Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 

91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). U.S. Dep’t of Transp. 3. 
The Extent of Relief Camera Artistry Photography Seeks and the Reason It Seeks Such Relief: Camera 

Artistry Photography 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 Camera Artistry 

Photography contemplated commercial cinematic, research and other flight operations within the 

national airspace system. 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. 

Our lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of our lightweight UAS is expressly contemplated by the Reform Act. We 

would like to operate our lightweight UAS prior to the time period by which the Reform Act requires 

the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determining 

the types of UASs that may operate safely in our national airspace system. Considerations include: • 

The weight, size, speed and overall capabilities of the UAS; • Whether the UAS will be operated near 

airports or populated areas; and, • Whether the UAS will be operated by line of sight. 112 P.L. 95 § 

333 (a). Each of these items militates in favor of an exemption for Camera Artistry Photography. Our 

UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs less 

than 5 pounds, including battery and all equipment. This small unmanned aircraft is designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. It is capable of vertical 

and horizontal operations but operate only within the line of sight of the remote control pilot. In 

addition to the remote control pilot, we us a spotter, such that, at minimum, two Camera Artistry

Photography personnel govern the safe flight of the aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and twenty 

minutes. We do not operate the UAS with less than twenty five percent battery capacity. Safety 

systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff 

location if communication with the radio control pilot is lost and then slowly descend the UAS at 

twenty five percent battery capacity. We generally do not operate the UAS near airports or near 

populated areas. To date, we have only operated the UAS in a noncommercial manner. Our operation 

of this small unmanned aircraft will not “create a hazard to users of the national airspace system or 

the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, combined with its 

operation in cordoned off and well-controlled areas, this falls within Congress’s contemplated safety 

zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the 

national airspace system. Indeed, our UAS will not pose any threat to the general public or national 

security. The FAA has the authority to issue the exemption sought by Camera Artistry Photography

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”). 4. How this Request 

Will Benefit the Public as A Whole: Granting this exemption request furthers the public interest. First, 

Congress has already pronounced that it is in the public’s interest to integrate commercially flown 

UASs into the national airspace system, hence the passing of the Reform Act. Second, Camera Artistry 

Photography conducts research into safe UAS operations every time it flies its UAS. Flight data, visual 

inspections, recorded observations and flight analyses are compiled to further enhance current safety 

protocols. Allowing us to log more flight time directly relates to our research and our ability to further 

enhance current safety measures. Third, the public has an interest in reducing the danger and 

emission associated with current aerial cinematic capture methods, namely, full size helicopters. Our 

UAS is battery powered and creates no emissions. If our UAS crashes there is no fuel to ignite and 

explode. The impact of our lightweight UAS is negligible when compared to a full size helicopter, 

notwithstanding the statistically noteworthy safety record of full size helicopters used in motion 
picture capture. The public’s interest is furthered by minimizing ecological and crash impacts by 

permitting photo and motion picture capture through our lightweight UAS. Progression of the arts and 

sciences has been fundamental to our society since its inclusion in the United States Constitution. 

Indeed, Congress mandated the integration of UASs into our national airspace system, in part, to 

achieve progression in this noteworthy, and inevitable, field. Permitting Camera Artistry Photography

to immediately fly within the United States furthers these goals. Whether it is the amalgam of 

scientific discoveries applicable to feature film making (including those drawing upon architecture, 

physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or 

advancements in equipment available to law enforcement personnel / first responders that does not 

cost millions of dollars, granting this exemption request substantially furthers the public’s interest in 

ways known and currently unknown. Granting this request will also allow small business owners and 

home owners to be able to afford high quality aerial images and video that they would otherwise 

have no access to due to several factors, cost being the biggest.

5. Reasons Why Camera Artistry Photography Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: This exemption will not 

adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting Camera Artistry 

Photography to log more flight time in FAA controlled airspace will allow us to innovate and 

implement new and novel, as of yet undiscovered safety protocols. In addition, we submit the 

following representations of enhancements to current aerial photo and motion picture capture 

techniques: • Our UAS weighs less than 5 pounds complete with all mounted equipment and battery; 

• We only operate our UAS below 400 feet; • Our UAS only operates for 5-20 minutes per flight; • We 

land our UAS when it reaches 25% battery power; • Our remote control pilot operates the UAS by line 

of sight; • Our remote control pilot has video backup should he somehow lose sight of the UAS; • We 

staff each flight with a remote control pilot and spotter with communication systems enabling real 

time communication between them; • Our UAS has GPS flight modes whereby it hovers, returns to 

takeoff position and then slowly lands if communication with the remote control pilot is lost or 

battery power is below 25%; • We actively analyze electronic flight data and other sources of 

information to constantly update and enhance safety protocols; • We conduct extensive briefings 

prior to flight, during which safety carries primary importance, and; • We have procedures in place to 

abort flights in the event of safety breaches or potential danger. Our safety protocols provide a level 

of safety at least equal to existing rules, and in nearly every instance, greater than existing rules. It is 

important to note that absent the integration of commercial UASs into our national airspace system, 

helicopters are the primary means of aerial motion picture capture. While the safety record of such 

helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight UAS. 

First, the potential loss of life is diminished because UASs carry no people on board and Camera 

Artistry Photography only operates them in specific areas away from mass populations. Second, there 

is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the 

small size and extreme maneuverability of our UAS allows our remote control pilot to avoid hazards. 

Lastly, given their small size and weight, even when close enough to capture amazing images, our UAS 

needs not be so close to the objects it is focused on. Accordingly, our UAS has operated and will 

continue to operate at and above current safety levels.

6. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness 
Certificates, sets forth requirements for procurement of necessary airworthiness certificates in 

relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of Camera Artistry 

Photography UAS permits exemption from Part 21 because Camera Artistry Photography UAS meets 

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 

(f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from 

the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. Camera Artistry Photography UAS 

meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 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 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, and given the size of the UASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight 

operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 

91.121 regarding altimeter settings is inapplicable insofar as Camera Artistry Photography’s UAS 

utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Camera Artistry Photography flight

operations center. B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal 

Regulation require aircraft to be marked according to certain specifications. Camera Artistry 

Photography UAS is, by definition, unmanned. It therefore does not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft. Regardless, Camera Artistry Photography will mark its UAS in the largest possible 

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so 

that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700.

C. 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. Camera Artistry Photography can 

achieve an equivalent level of safety as achieved by current Regulations because Camera Artistry 

Photography UAS does not carry any pilots or passengers. Further, while helpful, a pilot license for 

Larry L. Letzer Jr. will not ensure remote control piloting skills. As stated, Larry L. Letzer Sr. is an FAA 

certified aviator. Further, the risks attendant to the operation of Camera Artistry Photography UAS is 

far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

Thus, allowing Camera Artistry Photography to operate its UAS with a private pilot as the pilot in 

control will exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 C.F.R. 91.119: 

Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. 

It allows helicopters to be operated at lower altitudes in certain conditions. Camera Artistry 

Photography UAS will never operate at an altitude greater than 400 AGL. Camera Artistry 

Photography will, however, operate its UAS in cordoned off areas with security perimeters, providing 

a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of Camera Artistry Photograpy UAS, an equivalent level of safety 
will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have 

[the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to Camera Artistry should its requested exemption be granted. Camera 

Artistry Photography conducts an extensive maintenance program that involves regular software 

updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety 

will be achieved. F. Summary Camera Artistry Photography seeks an exemption from the following 

Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 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. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 

(a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a)(2); and, 14 C.F.R. §§ 91.417 (a) & (b) to 

commercially operate its lightweight unmanned aircraft vehicle in motion picture or photography 

operations and to conduct its own research. Granting Camera Artistry Photography request for 

exemption will reduce current risk levels and thereby enhance safety. Currently, motion picture image 

capture relies primarily on the use of larger aircraft running on combustible fuel. Camera Artistry 

Photography craft does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional motion picture aircraft. Further, Camera Artistry Photography

operates at lower altitudes and in controlled airspace. Camera Artistry Photography has been 

analyzing flight data and other information in compiling novel safety protocols and the 

implementation of a flight operations manual that exceeds currently accepted means and methods of 

safe flight. There are no people on board Camera Artistry Photography UAS and therefore the 

likelihood of death or serious bodily injury is significantly limited. Camera Artistry Photography

operation of its UAS, weighting less than 5 pounds and travelling at speeds lower than 50 knots in 

cordoned off areas will provide at least an equivalent level of safety as that achieved under current 

FARs. 

Accordingly, Camera Artistry Photography respectfully requests that the FAA grant its exemption 

request without delay. The FAA has the authority to issue the exemption sought by Camera Artistry 

Photography pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”). In 

closing, I would like to state that it would be very easy to ignore the FAA and operate a UAS 

commercially without applying for any consideration from them. I have seen and spoken with several 

people who are already doing so. I hope the simple fact that someone such as myself who operates a 

very small business and will be operating a UAS on a very small scale is applying for this exemption 

shows how serious I am about safety and doing things properly. Thank you very much for your time 

and consideration.

Respectfully submitted,

Larry L. Letzer Jr. Partner, Camera Artistry Photography 2908 Oak Hill Drive Copperas Cove, Texas 

76522