August 10, 2015 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Exemption Request Section 333 of the FAA Reform Act 

508 Productions, LLC. 

Chris Babiana 

Owner 

508-507-0415

Federal Aviation Administration: 

On behalf of 508 Productions, LLC, (and all other subsidiaries and DBA’s of 508 

Productions, LLC.) I would like to formally submit for an exemption from part 21, 

subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 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). This requested exemption 

would allow 508 Productions, LLC (and all other subsidiaries and DBA’s of 508 

Productions, LLC.) to pursue it’s interest of unmanned aircraft systems (UAS) for 

the purpose of aerial videography and photography for real estate, lifestyle, 

corporate, non-profit and all other business related productions requiring low 

altitude video/photo aerial operations. 

508 Productions, LLC (and all other subsidiaries and DBA’s of 508 Productions, 

LLC.) will operate various small UAS models (under 55 lbs), including but not 

limited to the FreeFly Cinestar8, DJI Inspire 1 and PHANTOM 3, which is 

comprised of an unmanned aircraft (UA or PHANTOM), an attached camera (or 

built in camera with DJI Inspire 1 and PHANTOM 3) and a transportable ground 

station. 

The DJI Inspire 1, DJI Phantom 3 and FreeFly Cinestar8 are battery powered 

and have built-in failsafe features which are automatically triggered in the event 

communication is lost between the UAS and the main controller transmitter and 

controller. At that time, the UAS will return to its point of takeoff and land safety. If 

the connection is restored, the PIC can regain control of flight and land manually. 
Operating Parameters: 

508 Productions, LLC (and all other subsidiaries and DBA’s of 508 Productions, 

LLC.) will comply with all of the following conditions and limitations: 

1) Operations will be limited to the aircraft as described above. 

2) The UA will not be flown at an indicated airspeed exceeding 30 knots. 

3) The UA will be operated at an altitude of no more than 400 feet above ground 

level(AGL). 

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In 

Command(PIC) at all times. 

5) All operations will utilize a visual observer (VO). The UA will be operated 

within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will 

be able to communicate verbally at all times. The PIC will be designated before 

the flight and will not transfer his or her designation for the duration of the flight. 

The PIC will ensure that the VO can perform the functions prescribed in the 

operating documents. 

6) The operating documents will be accessible during UAS operations and made 

available to the Administrator upon request. Any revisions to the operating 

documents will be presented to the Administrator upon request. 

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station will be included in the preflight inspection. All 

maintenance and alterations will be properly documented in the aircraft records. 

8) Any UAS maintenance or alterations that affect the UAS operation or flight 

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

functional test flight. The PIC who conducts the functional test flight will make an 

entry in the aircraft records. 

9) The pre-flight inspection section in the operating documents will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents. 
10) Follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

11) Carry out maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and 

alterations will be noted in the aircraft records, including total flight hours, 

description of work accomplished, and the signature of the authorized person 

returning the UAS to service. 

12) Each UAS operated will comply with all manufacturer Safety Bulletins. 

13) An authorized person will make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

14) UAS operations will be conducted by a PIC possessing at least a sport pilot 

certificate and at least a valid US drivers license. 

15) The PIC will not operate the UAS unless the PIC has demonstrated and 

logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate 

the UAS in a manner consistent with the operating documents, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

16) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

17) The UA will not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart. 

18) The UA will 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. 

19) If a UA loses communications or loses its GPS signal, it will return to a 

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

20) The PIC will abort a flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

21) The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 30% battery power remaining. 

22) The documents required under 14 CFR 91.9 and 91.203 will be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. 
These documents will be made available to the Administrator or any law 

enforcement official upon request. 

23) The UA will remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

24) The UAS will not be operated by the PIC from any moving device or vehicle. 

25) Flight operations will 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. We will 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 and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

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. 

26) All operations will be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

27) Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will 

be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

If you have questions or need additional information, please contact me at 

babs70111@gmail.com or 508-507-0415 

Thank you. 

Chris Babiana 

Owner 

508 Productions, LLC.