By letter dated July 14, 2014, Spencer Bramson, of 2296 Gloaming Way, Los Angeles, CA,

90210, petitioned the Federal Aviation Administration (FAA) for an exemption from part 21,

subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109,

91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption

would allow Bramson to operate the PHANTOM 3 drone unmanned aircraft system (UAS) to

conduct aerial videography and cinematography for recreational purposes as well as potential

marketing ventures to create high quality video footage for short films and/or advertisements.

Bramson will support his request with the following information:

Supporting documentation including: 1) Supplemental Response for Petition, 2) PHANTOM 3

Professional Quick Start Manual v1.0, 3) PHANTOM 3 User Manual v.1.2, 4) personal protocols

and controls.

Unmanned Aircraft System

Bramson states that he plans to operate the PHANTOM 3, which is comprised of an unmanned

aircraft (UA) and a remote control operating unit.

The PHANTOM 3 is considered to be a video taking quad­copter. The UA weighs approximately

1280g while operating at a maximum speed of 35mph. The UA is powered by rechargeable

batteries that last 23 minutes of flight and is equipped with four rotors. The camera attached to

the UA is permanent and cannot be removed. The main use of intent would be

recreationally/small for hire marketing assignments. He hopes to be able to create meaningful

videos and short advertisements that would appeal to the public.

Bramson follows a personal code of conduct to operate under a safe environment and to adhere

to policies in place for the safety of the general public. Bramson will operate regarding rules:
● Conducting extensive preflight inspections of equipment and the environment where he

is flying to maximize safety precautions.

● Only operating in controlled locations that will emit an aura of safety away from

hazardous variables such as arena lights, airports, power lines, and highly active and

populated areas.

The petitioner states that given the size, weight, speed, and limited operating area associated

with the aircraft to be utilized by him

Based on the size, weight, and speed of the UA, Bramson requests an exemption from 14 CFR

part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required),

subject to certain conditions and limitations, is warranted and meets the requirements for an

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112­95 (Section 333).

Secondly, Bramson requests the exemption from § 45.23 Marking of the aircraft. The UA does

not have a large enough surface for visible writing. However, as required by § 45.29(f), Bramson

will mark the fuselage with “Bramson UA” as large as the fuselage will permit to indicate to

anyone the markings and ownership.

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and

91.417(a) and (b) Maintenance inspections may be required and should be granted since they

only apply to aircraft with an airworthiness certificate. To his ability, Bramson will practice a

preflight safety inspection as a safety precaution before each flight.

UAS Pilot in Command (PIC)

The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to non

commercial operations. Since the PHANTOM 3 UA does not hold passengers or transports any
goods, Bramson believes that a pilot license will not be necessary to control a remote controlled

aircraft. The risks of operating a UA is less than those of commercial activities stated in 14 CFR

part 61 and therefore requests that he be exempt from § 61.113 Private Pilot Privileges and

Limitations: Pilot in command.

In conclusion, Bramson petitions for an exemption from part 21, subpart H; and Sections

45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a),

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code

of Federal Regulations (14 CFR) for uses of a personal PHANTOM 3 UA to create short films

for recreation, promoting his personal brand, or any other marketable ventures.