December 21, 2015

Joel Smith

Comprehensive Media, Inc.

214 Overlook Circle

Suite 180

Brentwood, TN 37027

jsmith@comprehensivemedia.com

615.866.3150 

Federal Aviation Administration:

Comprehensive Media, Inc. and its President, Joel Smith, hereinafter referred to collectively as 

(“CMI”), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that CMI, an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so 

that CMI may operate a small ultra light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in 

accordance with FAA UAS Regulations & Policies. 

CMI would like to formally submit itself all of its UAS pilots for an exemption from the 

following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 

14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 

91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate a Phantom 2 Vision+ UAS 

manufactured by DJI, which will be equipped with detachable cameras and will be transported in 

proper storage. 

This proposed exemption would allow CMI operation of unmanned aircraft systems (UAS) for 

the purpose of aerial videography/photography as a service to the public/business interests. As 

found in exemption No. 11138 (Trudeau), the FAA recently approved similar use of DJI UAS. 

These devices were selected because they have proven to have reliable flying capabilities 

managed by GPS stabilized flight and hovering, ground detection, GPS aided navigation, a 

compass, blinking LEDs, failsafe mode for returning home, self tightening propellers and no fly 

zones feature.
This will act to further safety protocols exclusive to lightweight UAS’s specific to video and 

photography usage as CMI records flight data and other information gained through permitted 

flight operations to share with the FAA through any required FAA reports to assists with future 

protocol and safety regulations. Specific section or sections of 14 CFR which I seek relief and 

the reason I seek relief: 14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited 

operating area associated with the aircrafts to be utilized by CMI an exemption from Part 21 

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

reform Act. 

In all cases, an analysis of these criteria demonstrates that the UA operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be 

at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate 

without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The 

UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain 

words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement. 14 C.F.R. 61.113(a) & (b): Private 

pilot privileges and limitations: Pilot in command The FAA has previously declared that 

additional manned airship experience of a commercially certified pilot would not correlate to the 

airmanship skills necessary for similarly proposed operations in previously issued exemptions to 

this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft 

airworthiness Currently, since there is no certificate applicable to the UAs in question, this 

regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and 

placard requirements Requires an aircraft flight manual in the aircraft, however there are no 

pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual with the 

operator. 14 C.F.R. 91.119(c): Minimum safe altitudes CMI will ensure that UAS do not operate 

any higher than 400 feet at ground level. I will not fly over congested areas. I will plan 

operations before hand, for proper flight safety, and proper height analysis as to avoid collisions. 

14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometric sensor. 

An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel 

Requirements for flight in VFR conditions The UAS that I will fly are powered by electricity, 

using lithium polymer batteries that currently have a flight limit of approximately no more than 

25 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply 

with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications Required - Currently, 

there are no procedures for providing airworthiness certificates for the mentioned UAS. 

CMI will always fly safely while having the manuals of the DJI Phantom 2 Vision+. 14 C.F.R. 

91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 

14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and 

should be granted since they only apply to aircraft with an airworthiness certificate. However, 

CMI will perform preflight inspections of the UAS before each flight as outlined in the operating 

documents. CMI will also follow manufacturer recommendations from said operating 

documents. Also as mentioned in the Trudeau exemption, exemption No.11138: “Manned 

aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by 

an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of 
fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located 

from the aircraft. The limited weight reduces the potential for harm to persons or damage to 

property in the event of an incident or accident. The risk of an onboard pilot and crew during an 

incident or accident is eliminated with the use of a [sUAS] for the proposed operation.”

CMI is seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 

C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 

91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b) With the exemptions 

of the mentioned rules CMI will be seeking to make drone photography/videography services 

available to the public. 

Alternatively the public has looked to use helicopters and aircraft to achieve what CMI can offer 

in a safer, more cost efficient manner. By not using combustible fuel, flying at safe heights and 

strictly following the usage recommendations from DJI. These include but are not limited to: 

● Flying the following UAS Safely 

○ DJI Phantom 2 Vision+

● Flying below 400 feet 

● Proper visual inspection of UAS before flights 

● Keeping mentioned UAS in visual sight at all times when in operation 

● Using an observer to assist if needed 

● Remaining well clear of and do not interfere with manned aircraft operations, and 

avoid other aircraft and obstacles at all times 

● Not intentionally fly over unprotected persons or moving vehicles 

● Contacting the airport or control tower before flying within 5 miles of an airport 

● Not flying in adverse weather conditions such as high winds or reduced visibility 

● Not flying under the influence of alcohol or drugs 

● Ensuring the operating environment is safe 

● Not flying over sensitive infrastructure or property such as power stations, water 

treatment facilities, correctional facilities, etc. 

● Checking and following all local laws and ordinances before flying over private 

property 

● Not conducting surveillance or photograph persons in areas where there is an 

expectation of privacy without the individual's permission. 

Kind regards, 

Joel Smith

Comprehensive Media, Inc.

214 Overlook Circle, Suite 180

Brentwood, TN 37027

jsmith@comprehensivemedia.com

615.866.3150