Larry	W	Pittman,	President	and	Executive	Producer

Clear	Production	Services,	LLC.	dba	Vortex	Creative	Media

PO	Box	178

Cornville,	AZ		86325

www.vortexcreativemedia.com

www.clearproductionservices.com

email:	larry.pittman@mac.com

Phone:	928-277-6166

Submitted	September	1,	2015

United	States	of	America

Department	of	Transportation

Federal	Aviation	Administration

Washington,		DC

RE:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act,	Pursuant	to	

Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	Regulations	from:	

14	CFR	21	subpart	H

I,	Larry	William	Pittman	do	hereby	respectfully	request	exemption	relief	from	the	

requirements	of	Title	14	of	the	Code	of	Federal	Regulations	in	the	following	areas	

concerning	commercial	operations	of a DJI	Inspire	1	Unmanned	Aircraft	System

pursuant	to	Section	333	of	the	Federal	Aviation	Administration	Reform	Act	of	2012	and	

14	C.	F.	R.	Part	11	of	the	Federal	Aviation	Regulations:

14	CFR	45.23(b)	

14	CFR	61.113(a)	and	(b)	

14	CFR	91.7(a)	

14	CFR	91.9(b)(2)	

14	CFR	91.103	

14	CFR	91.109	

14	CFR	91.119(c)	

14	CFR	91.121	

14	CFR	91.151(a),	(b)	

14	CFR	91.203	(a)	and	(b)	

14	CFR	91.405	(a)	

14	CFR	91.407	(a)	(1)	

14	CFR	91.409	(a)(1)	and	(2)	

14	CFR	91.417(a)	and	(b)	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	
Act”)	and	14	CFR	Part	11,	Larry	W	Pittman,	operator	of	an	Unmanned	Aircraft	System

(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	

(“FARs”)	to	allow	commercial	operation	of	designated	UAS,	provided	such	operations	

are	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	established	

by	the	FAA	as	required	by	Section	333.	

Commercial	operation	of	an	UAS,	as	described	herein,	which	is	equipped	with	camera(s)	

and	sensors,	would	provide professional	services	in	the	following	areas:

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	

architecture,	land	surveying,	engineering	and	other	related	professional	activities.	

2.	Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	

public	events,	cinematography,	and	newsgathering.	

3.	Aerial	inspection/photography	of	residential/commercial	structures	under	contract	

with	the	owners	or	local	government	authority.

4.	Aerial	inspection/photography	of	residential/commercial	structures	and/or	land	being	

marketed	for sale.

5.	Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	

including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.	

6.	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and rescue	

operations	in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	

or	government	has	requested	it	by	contract	or	donation.	

7.	Training	to	persons	individually	or	belonging	to	both	private	and/or	public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	within	the	NAS.	

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	

designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	

that would	be	a)	Limited; b)	controlled; c)	predetermined	and; d)	safe.	Approval	of	this	

exemption	would	increase	public	awareness	of	UAS	operations	and	enhance	safety	to	

aid	in	fulfilling	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	

responsibilities	to	“....establish	requirements	for	the	safe	operation	of	such	aircraft	

systems	in	the	national	airspace	system.”	

Larry	William	Pittman plans to	operate	the	DJI	Inspire	1	(UAS)	which	is	comprised	of	an	

unmanned	aircraft	(UA	or	Inspire	1),	a	Ground	Control	Station,	utilizing	an	electronic	

tablet	or	smart	phone	systems	for	control	of	the	UA.	The	Inspire	1	is	referred	to	as	a	

quad-copter	with	a	maximum	gross	weight	of	6.47	pounds.	It	is	equipped	with	four	main	

rotors;	driven	by	Lithium	Polymer	battery	powered	electric	motors.	The	UA	has	a	

maximum	airspeed	of	22	m/s.	Also,	given	the	small	size	of	the	UAS	involved	and	the	

restricted	controlled	environment	within	which	it	will	operate,	the	applicant	fits	within	

that	zone	of	safety	(an	equivalent	level	of	safety)	in	which	Congress	envisioned	that	the	

FAA	must,	by	exemption,	allow	commercial	operations	of	UASs	to	commence	

immediately.	Also	due	to	the	size	of	the	UAS	and	the	controlled	areas	in	which	the	
relevant	UASs	will	operate,	approval	of	the	application	presents	no	national	security	

issue.	In	consideration	of	the	speed,	weight,	size,	and	limited	operating	area	associated	

with	the	unmanned	aircraft	and	its	operation,	the	DJI	Inspire	1	UAS	meets	the	condition	

of	FMRA	Section	333	and	therefore,	will	not	require	an	airworthiness	certificate	in	

accordance	with	14	C.F.R.	Part	21,	Subpart	H.	

Furthermore,	Larry	William	Pittman,	who	will	be	pilot	in	command	of	the	DJI	Inspire	1	

UAS	is	uniquely	qualified	to	perform	safe	operations	of	the	craft.	Larry	William	Pittman	

is	a	licensed	commercial	pilot	with	over	3500	accident	free	hours	as	Pilot	in	Command	of	

single	engine	general	aviation	aircraft.	Most	of	those	hours	were	accumulated	as	a	flight	

instructor,	teaching	safe	aircraft	operations	to	his	students	as a	top priority.		In	addition,	

Larry	William	Pittman	has	over	10	years	experience	flying	radio	controlled	aircraft	as	a	

personal	hobby.	Finally,	Larry	William	Pittman	has	11	years	experience	in delivering	high	

quality	moving	and	still	images	on	movie	and	corporate	sets	for	clients.

Given	the	following,	the	grant	of	the	requested	exemptions	is	clearly	in	the	public	

interest.	Granting	the	present	Petition	will	allow	Larry	William	Pittman	to	safely,	

efficiently,	and	economically	perform	aerial	video	and	photography	over	certain	areas	of	

the	United	States.

Additionally,	use	of	the	DJI	Inspire	1	UAS	will	decrease	congestion	of	the	NAS,	reduce	

pollution,	crashes	and	accidents	caused	by	pilot	error	and	provide	significant	benefits	to	

the	economy	without	implicating	any	privacy	issues.

Because	the	DJI	Inspire	1	UAS	is	battery	powered,	utilization	of	the	UAS	would	reduced	

noise	and	air	pollution,	as	well	as	increase	the	safety	of	life	and	property	in	the	air	and	

on	the	ground.	Likewise,	a	reduction	of	manned	aircraft	conducting	aerial	video	and	

photography	missions	would	result	in	fewer	aircraft	that	must	be	handled	by	air	traffic	

control	during	the	ground,	takeoff,	departure,	arrival,	and	landing	phases	of	flight	

operations.

Conducting	aerial	video	and	photograph	asset	acquisitions	with	the	DJI	Inspire	1	UAS,	

instead	of	manned	aircraft,	will	benefit	the	economy.	The	DJI	Inspire	1	is	an	economical	

alternative	to	using	manned	aircraft	to	conduct	similar	aerial	operations.		Use	of	the	DJI	

Inspire	1	will	allow	United	States	based	companies	to	remain	competitive	and	

contribute	to	the	growth	of	the	U.S.	economy.	Operating	the	battery	powered	DJI	

Inspire	1	UAS	is	a	technology	that	not	only	allows	companies	greater	operational	

flexibility	compared	to	manned	aircraft,	but	provides	such	flexibility	without	high	

operational	cost	of	a	traditional	manned	aircraft.

Conducting	aerial	search	and	rescue	operations with	the	DJI	Inspire	1 on	a	requested	

basis	by	local	and	state	authorities	will	enhance	life	and	health	of	those	who	have	

become	lost	or	incapacitated	while	hiking	in	wilderness	areas	by	bringing	lower	cost	

technology	to	the	scene	to	allow	first	responders	to	monitor	actual	conditions	via	
downlink	from	on-board	video	cameras.	

Larry	William	Pittman’s	proposed	operation	of	the DJI	Inspire	1	UAS	will	not	implicate	

any	privacy	issues.	Specifically,	the	DJI	Inspire	1	UAS	will	be	operated	only	in	compliance	

with	operating	documents	(i.e.,	Aerial	Operations	Manual,	Monthly	Maintenance	Log,	

and	DJI	Inspire	1	Instruction	Manual),	which	requires	property	owner	involvement	as	

will	as	local	law	enforcement	notification.

Larry	W	Pittman	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These	

limitations	provide	for	an	exceptional	level	of	safety	to	operations.	These	limitations	and	

conditions	to	which	Clear	Production	Services,	LLC,	dba	Vortex	Creative	Media	and	Larry	

W	Pittman	agrees	to	be	bound	when	conducting	commercial	operations	under an	FAA	

issued	exemption	including:	

1.	The	UAS	will	weigh	less	than	55	lbs.	

2.	Flights	will	be	operated	within	line	of	sight	of	operator.	

3.	Maximum	total	flight	time	for	each	operational	flight	will	be	20 minutes.	

4.	Flights	will	be	terminated	at	15% battery	power	reserve.	Additionally,	Larry	William	

Pittman	seeks	an	exemption	from	the	requirements	of	Section	91.151	(b),	entitled	Fuel	

requirements	for	flight	in	VFR	conditions.	Larry	William	Pittman	submits	that	safety	will	

not	be	affected	by	operating of	the	DJI	Inspire	1	UA	during	daylight	hours	in	visual	

meteorological	conditions	under	visual	flight	rules	(VFR),	with	enough	battery	power	to	

fly	for	a	total	duration	of	approximately	15.5	minutes	to	the	first	point	of	intended	

landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	minutes.

5.	Flights	will	be	operated	at	an	altitude	of	at	or	below 200	feet	AGL.	Larry	William	

Pittman	also	seeks	exemption	from	the	requirements	of	Section	91.121,	entitled	

Altimeter	Settings,	as	the DJI	Inspire	1	UA	will	not	have	a	typical	barometric	altimeter	

onboard.	However,	altitude	information	of	the	DJI	Inspire	1	UA	will	be	provided	to	the	

PIC	via	Global	Positioning	System	(GPS)	equipment	and	radio	communications	telemetry	

data	link,	which	downlinks	from	the	UA	to	the	GCS	for	active	monitoring	of	the	flight	

path.	This	altitude	information,	combined	with	Larry	William	Pittman’s	operation	of	the	

DJI	Inspire	1	UAS	within	visual	line	of	sight,	at	or	below	400	feet	AGL,	will	ensure	a	level	

of	safety equivalent	to	Section	91.121.	

6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	Procedures.	

7.	The	operator	will	post	advisory	notice	around	the	controlled	area.	

8.	The	operator	will	have	been	trained	in	operation	of	UAS	generally	and	received	up-todate	information	on	the	particular	UAS	to	be	operated	as	required.	

9.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	

return	to	a	pre-determined	location	within	the	Security	Perimeter	and	land.

10.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.	

11.	All	flights	will	be	line	of	sight	and	with	utilization	of	a	safety	observer.

12.	The	DJI	Inspire	1	UAS	does	not	require	an	airworthiness	certificate	in	accordance	
with	14	C.F.R.	Part	21,	Subpart	H.	As	such,	each	UAS	flight	will	begin	with	a	thorough	

preflight	inspection	of	the	UAS	and	related	systems	as	established	by	company	

procedures	and	in	accordance	with	operation	and	maintenance	material	supplied	by	DJI	

to	ensure	that	the	UAS	is	in	an	airworthy	condition	prior	to	every	flight.

13.	Larry	William	Pittman	will	use	experienced	personnel	or	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UAS	using	the	methods,	

techniques,	and	practices	prescribed	in	the	operating	documents	for	the	DJI	Inspire	1.	

Furthermore,	Larry	William	Pittman	will	document	and	maintain	all	maintenance	

records	for	the	DJI	Inspire1	UAS.

14.	UAS	will	be	piloted	by	a	UAS	trained	pilot	holding	valid pilot	certificate	and	medical	

certificate	under	14	CFR	Part	61.	

15.	The	DJI	Inspire	1	UA	that	will	be	operated	by	Larry	William	Pittman	will	be	registered	

in	accordance	with	49	U.S.C.	44103,	Registration	of	Aircraft,	as	well	as	14	CFR	Part	47,	

Aircraft	Registration,	and	marked	in	accordance	with	14	C.F.R.	Part	45,	Identification	and	

Registration	Markings.

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	

exemption	and	are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	

need	for	an	equivalent	level	of	safety.	We	look	forward	to	working	with	your	office.	

Please	contact	us	at	any	time	if	additional	information	or	clarifications	are	needed.	

Sincerely,	

Larry	W	Pittman