Wood River Video Exeter RI - Section 333 Exemption Petition

March 1, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590

PURPOSE:

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

C.F.R.45.23(b); 14 C.F.R. Part 21; 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)&(b); 14C.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. 91.417(a)&(b)

SUMMARY:

Pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, Wood River Video, an veteran owned and operator of small unmanned aircraft systems 

Owned and operated by Frank J Thoman a master aviator and military instructor pilot who holds a 

private pilots license and has flown rotorcraft in 5 different countries amassing over 2100 hours of flight 

time. I hereby request to be exempted from the Federal Aviation Regulations (FARs) listed below so that 

Wood River Video, may safely and legally operate unmanned aircraft systems (UAS) in the national 

airspace (NAS) regulated by the Federal Aviation Administration FAA. Following exemption and 

approval by the FAA, Wood River Video will be responsible for the Pilot in Command (PIC) of a 

professionally built, camera-equipped DJI Inspire 1 and a DJI Phantom 3 Professional UAS for the 

following applications: closed-set film operations for the motion picture, television and commercial

productions, on-location film operations in controlled settings on private land or with property 

permission; augmentation of real-estate listing videos only with express permission of the property 

owner; land surveying and the creation of visual and topographical layout videos for state and local 

agencies, educational organizations, agricultural inspections or building and construction zone 

inspections, provided that such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. Granting exemption to Wood 

River Video would permit the above specified operation of ultra lightweight sUASs in the NAS with 

limited, tightly controlled, and predetermined flight plans away from the general public, airports, 

heliports, motorways or any restricted airspace. Granting a request for Wood River Video complies with 

the Secretary of Transportation’s (FAA Administrator’s) instructions to integrate sUASs into the national 

airspace system, as well as to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of

UAS's for real estate/realtor purposes, educational videos, search and rescue, land/trusts inspections, 

agricultural field monitoring, film/video productions, closed-set motion picture film and television 

operation, and structure inspections, to aid private, state and local agencies. Wood River Video will 

ensure enhanced public safety by conducting operations in compliance with the specific safety protocols 

and regulations established by the FAA. Additionally, seamlessly integrating sUASs into the NAS will 

increase community awareness to the benefits of the UAS industry. Increased awareness and education 

will reveal the positive role the UAS industry can play in local communities while increasing safety.
I. Contact Information:

Wood River Video

Frank J Thoman

Phone: 401-932-9830

Email: woodrivervideo@gmail.com

Address: 653 Ten Rod Rd

Exeter, RI 02822

II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which Wood River Video 

Requests Exemption are:

14 C.F.R. 21;

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

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) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

This exemption application is submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of 

The Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in the national airspace (NAS) before completion of the rule making 

required under Section 332of the Reform Act. In making this determination, the Secretary is required to 

determine which type of UAS’s do not create a hazard to users of the NAS or the public or pose a threat 

to national security. If the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333 (c) (emphasis added). The Federal Aviation Act expressly grants the 

FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil 

aircraft, as the term is defined under §40101 of the Act, that includes UASs, from the requirement

that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or 

any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 

U.S.C. § 44701 (f) See also 49 U.S.C. §44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1).
III. The Extent of relief Wood River Video Seeks and the Reason He Seeks Such Relief:

This exemption application is submitted on behalf of Wood River Video in accordance with the Reform 

Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

Wood River Video, predetermined commercial cinematic, academic and other flight operations within 

the NAS. 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. ANR Production Services, 

Incorporated will be operating lightweight UASs that meet the definition of “small unmanned aircraft” 

as defined in Section 331 and, therefore the integration of such UASs are expressly contemplated by the

Reform Act.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with 

the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

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

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

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated 

hereunder is 55 lbs. or less fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the operator 

and under the requirements and in compliance with local public safety requirements, to provide security 

for the area of operation as is now done with conventional filming. The FAA will have advance notice of 

all operations. These safety enhancements, which already apply to civil aircraft operated in connection

with motion picture and television production, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the 

Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, the operator must also display on 

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words "limited", "restricted", "light-sport", "experimental", or 

"provisional", as applicable. Even though the UAS will have no airworthiness certificate, an exemption 

may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer, and others working with the UAS will see the identification of the 

UAS as “Experimental”. The FAA has issued the following exemptions to this regulation as Exemption 

Numbers 10700,8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113 

(a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or 

passengers, the proposed operations can achieve the equivalent level of safety of current operations by 

requiring the PIC operating the aircraft to have no less than 40 hours of flight time with the specific UAS 

equipment ANR Production Services, Incorporated operates. The experience of the PIC will be certified 

by Wood River Video through background checks and, if necessary, testing. Wood River Video will 

maintain flight logs of all PICs it employs, and provide full transparency to the FAA regarding the logs 

and records of these PICs. The PIC designated for any operation will hold an FAA airman’s certificate and 

have at least a Class 2 medical certificate or valid Driver’s License. The risks associated with the 

operation of the UAS are so diminished from the level of risk associated with commercial operations on

templated by Part 61 when drafted, that allowing operations of the UAS by a PIC meeting the standards 

of Wood River Video (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) 

& (b). Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled 

with no persons on board. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance. Currently there are no pilot licenses that are specific for UAS operators, and 

no current FAA sanctioned pilot license. Our company with the extensive pilot and safety training of the 

owner would be a perfect example for the granting of an exemption. In addition our company would 

also be happy to work with the FAA to help develop the standards for new licenses, and any other 

regulations the FAA is developing for UAS operation.

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. The regulation requires that no person may operate a 

civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the 

UAS aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance, and use of safety check lists prior to each 

flight (summaries listed below), an equivalent level of safety will be provided. Summarized Safety 

Checklists: Aircraft: All adjustment points will be checked for tightness; all motors and props will be 

inspected; all wiring will be double checked; all systems will be powered up and checked for errors.

Battery: Confirmation will be made that batteries are fully charged and installed/connected properly.

Calibration: Pre-flight motor/gyro calibration followed by confirmation of no errors with the flight and 

navigation systems. Compass Calibration: compass will be calibrated at each new location as per 

manufacturer’s protocols. Transmitter: Confirm radio transmitter has sufficient charge, and is both 

working properly and receiving telemetry from the UAS; confirm all switches are in pre-flight mode.

Surroundings/Flight Area: Conduct one last visual inspection of the take-off surroundings and area of 

airspace UAS will be operating in. Confirm all people in the surrounding areas are associated with the 

filming being done. Take-off Announcement: Before motors are started the PIC will announce to a 

designated Representative (person of authority) of the film crew that UAS is ready to take-off. Only after 

the Representative has notified all persons within the surrounding areas, and confirmed to PIC that they 

have clearance to lift-off, will the motors be started and the UAS will conduct its operation. Test Flight: A 

test flight will be conducted: after any disassembly/reassembly; after replacement of any motors or

flight electronics; after any pre-flight or in flight equipment errors that occur not resulting from 
environmental conditions; very first thing of any commercial operations day before filming begins; if 

there are any concerns about environmental conditions and potential issues with the flight path.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No 

person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the flight manual at the ground control point where the PIC flying the UAS will have immediate 

access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command to take certain 

actions before flight to ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight.

14 C.F.R. § 91.109: Flight instruction: Section 91.109 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. UASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilot 

nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of 

civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 feet AGL, or not more than 200 feet above an elevated 

platform from which filming is planned, an exemption may be needed to allow such operations. As set 

forth herein, the UAS will never operate at higher than 400 feet AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 

feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. It

will however be operated in a restricted area with security perimeter, where buildings and people will 

not be exposed to operations without their pre-obtained consent. The equivalent level of safety will be 

achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight

will be taken without the permission of the property owner or local officials. Because of the advance 

notice to the property owner and participants in the filming activity, all affected individuals will be 

aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations
of the UAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121 Altimeter Settings This regulation requires each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent 

level of safety will be achieved by the operator, pursuant to the safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an

individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, 

assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes.” The battery powering the UAS provides no more than 30 

minutes of powered flight. 14 C.F.R. § 91.151, UAS flights would not be possible due to the reserve 

requirement being equal to the maximum flight time. Given the limitations on the UASs proposed flight 

area and the location of its proposed operations within a predetermined area, a longer time frame for 

flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 

C.F.R. § 91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a

tightly controlled area where only people and property owners or official representatives who have 

signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of 

risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, the limitations created by this requirement for UAS flights would essentially make null any 

utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 18 minutes or 30% of battery power— whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from anywhere 

in its limited operating area. Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration The regulation 

provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: (1) An appropriate and current airworthiness certificate. (b) No 

person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs.

and is operated without an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. An equivalent level of safety will be achieved by 

keeping these documents at the ground control point where the pilot flying the UAS will have

immediate access to them, to the extent they are applicable to the UAS. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections These regulations 

require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or 
maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to 

aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance and 

inspections will be done in accordance with the UAS Manufacturer's Manual, and will be performed by 

employees of Wood River Video following the guidelines and practices provided to us by the UAS 

Manufacturer. An equivalent level of safety will be achieved because these small UASs are very limited 

in size and will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 

feet AGL. The PIC will ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the PIC is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

Additional Views and Information: Wood River Video has realized the amazing benefits UAS equipment 

can provide to the film and television industries. It not only provides new cinematography capabilities, 

but also increased safety over current and past practices that used larger and more dangerous

equipment. Our company wants to have the highest levels of safety and professionalism, and one thing 

essential to this is achieving a path to commercial licensing with the FAA. We believe this will help 

reduce unsafe practices, discourage improper uses, and improve public perception. The commercial 

manufacture and use of UAS equipment will create more jobs for the United States and help boost the 

economies in many sectors, and we want to help the FAA in creating regulations that will allow 

incorporation of UAS devices into our country's airspace for commercial use.

IV. Reasons Why Wood River Video Exemption Will Not Adversely Affect Safety and How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

The applicant 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 at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations are conducted in limited areas with predetermined flight paths under 

the permission of the property owner or property representative. These limitations and conditions to 

which Wood River Video agrees to be bound when conducting commercial operations under an FAA 

issued exemption include:

1. The UAS will weigh no more than 55 lbs.

2. Flights will be operated within line of sight (VLOS) of the pilot in command (PIC) or visual observer 

(VO).

3. Maximum total flight time for each operational flight will be 18 minutes or at 30% battery power 

reserve should that occur prior to the 18 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned. If a structure being filmed or photographed has a 

height which exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the highest point 

on that structure.

5. Minimum crew for each operation will consist of the UAS PIC, and the Visual Observer.

6. UAS Pilot will be Pilot in Command (PIC). The PIC hold at least an FAA airman certificate and will have 

a minimum of 40 hours of flight time with the specific UAS equipment Wood River Video operates. The

experience of the PIC will be certified by Wood River Video through background checks and, if 

necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test 
Code: PAR or PRH). Wood River Video will maintain flight logs of all PICs it employs, and provide full 

transparency to the FAA regarding the logs and records of these PICs.

7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver 

in advance of the operation.

8. A briefing will be conducted in regard to the planned UAS operations prior to each day’s production 

activities. It will be mandatory that all personnel involved with the operational duties of the flight within 

the boundaries of the safety perimeter be present for this briefing.

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local Flight Standards District Office.

10. The operator will obtain the consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 100 feet of the flight operation, and this radius may be 

reduced to 30 feet based upon an equivalent level of safety determination. With the advanced 

permission of the relevant FSDO, operations at closer range can be approved.

11. PIC and Visual Observer will have been trained in the operation of the specific UAS equipment used 

by Wood River Video, and received up-to-date information on the particular UAS to be operated.

12. The PIC designated for any operation will have at least a Class 2 medical certificate or valid Driver’s

License.

13. Visual Observer and PIC will at all times be able to communicate by voice, or radio.

14. Written and/or oral permission from the relevant property holders or property representatives will 

be obtained.

15. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate government agencies.

16. If the UAS loses communication with the PIC or loses its GPS signal, the UAS will have the capability 

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

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

emergencies. This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rule making required under Section 332 of the Reform Act. In making 

this determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 If the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333 (c) The Federal Aviation Act expressly grants the FAA the authority 

to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, that includes UASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate. The Administrator may grant an exemption from a requirement 

of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701 (f) See also 49 

U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1). Wood River Video UASs are rotorcraft, 
weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no 

more than 40 knots and have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in line of sight and will operate only within a predetermined and 

closed off property area under the permission of the property representative. Such operations will 

ensure that the UAS will “not create a hazard to users of the national airspace system or the public” as 

per the Reform Act Section 333 (b). Given the small size of the UASs involved and the restricted sterile 

environment within which they will operate, the applicant falls squarely 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 UASs and the 

restricted areas in which the relevant UASs will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, reduction in environmental

impacts, including reduced emissions associated with allowing UASs for movie and commercial 

videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the 

applicant respectfully requests that the FAA grant the requested exemption without delay.

V. How granting Wood River Video Exemption will Benefit Public as a Whole

The economic potential of the rapidly developing UAS industry is extraordinary. Technological 

advancements have created devices that were unthinkable as early as 5 years ago. Unfortunately this 

developing science has put advanced technology into the hands of untrained individuals. Further 

development of the UAS industry is dependent upon safe integration into the NAS. It is imperative that 

responsible operators lead by example in this developing industry in order to maintain the safest 

national airspace system in the world. When operated responsibly, unmanned aircraft systems pose 

significantly less threat to persons and property than traditional manned aircraft due to their size and 

lack of combustible material onboard. Congress has already proclaimed that it is in the public’s best 

interest to integrate commercially flown UASs into the NAS. The film and television industry is an ideal 

application of UAS technology. UASs are ideal in this industry in that they create less environmentally

Damaging emissions, are less disruptive locally and pose significantly less threat to persons and property 

than traditional aircraft. Granting exemption to Wood River Video will ensure more qualified,

responsible UAS operation in the NAS and can enhance the economic impact of the developing UAS and 

ancillary industries as a whole. ********* Pursuant to 14 C.F.R. Part 11, the following summary is 

provided for publication in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules:

14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (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); 91.409 

(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) in motion 

picture, television, and commercial operations. Specifically, Wood River Video is seeking 333 exemption 

for closed-set film operations for film and television productions, on-location film or television 

operations on private land or with property permission; aerial video support for films and commercials 

in controlled environments; augmentation of real-estate listing videos; and the creation of visual and 

topographical layout videos for state and local agencies, educational organizations, agricultural 

inspections or building and construction zone inspections. The UASs will carry no passengers or crew 

and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation 
of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide 

an equivalent level of safety supporting the grant of the exemptions requested herein, including

Exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating in close 

proximity to the ground and people. All flights will occur over private or controlled access property with 

the property representative or owner’s prior consent and knowledge. Filming will be of people who 

have also consented to being filmed or otherwise have agreed to be in the area where filming will take 

place. All flights will occur in accordance with any state or local laws regarding privacy. Satisfaction of 

the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, operating 

capabilities, proximity to airports and populated areas and operation within visual line of sight and

national security – provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of applicant’s UAS equipment in the motion picture, television, and 

commercial production industry.********** Traditionally, aerial filming for the television and film 

industries has relied primarily on the use of traditional aircraft. These larger combustible-fueled aircraft 

pose significant risk to the crew, passengers and the public in general due to their inherent dangers and 

the proximity of use to participants. Small unmanned aircraft are ideal for the television and film 

industries because of the same reasons they do not pose significant threat to the public. UASs

Do not carry combustible fuel, they have a lighter impact on the environment, are less disruptive, 

smaller, more maneuverable and safer than conventional video and photographic aircraft. When 

operated responsibly, a UAS utilizes lower altitudes within visual line of sight of the PIC in a 

predetermined airspace. These protocols further reduce the risk of personal injury or property damage. 

Since UASs are unmanned, risk to pilots and crew are practically impossible. In many ways UASs are 

ideal for the film and television industries and they will be responsible for enhancing production value in 

unexpected ways. As this technology becomes more ubiquitous UAS operation needs to be regulated 

effectively. The rapid development of UAS technology has made the need for effective legislation more 

pertinent. The UAS industry needs qualified, responsible operators to lead by example to help ensure 

safe integration into the NAS. Granting a 333 exemption for Wood River Video will reduce the reliance 

on traditional large aircraft for aerial video work and guarantee safe integration of additional UASs into 

the NAS, further reducing risk and enhancing public safety.

Respectfully submitted,

Wood River Video

Attn: Frank J Thoman

Address: 653 Ten Rod Rd

Exeter RI, 02822

Phone: 401-932-9830

Email: thebear33126@gmail.com
Appendix A – List of Unmanned Aircraft Systems UAS

Make & Model Description Serial # Registration # N-# Weight

DJI Inspire 1

4 rotor electric Wt. 7 lbs.

Unmanned aircraft System UAS

DJI Phantom 3

4 rotor electric requested 4 lbs.

Unmanned aircraft System UAS

Operating Frequencies: Transmitter: 2.400 ~ 2.483 GHz

Video Feed: 5.725 ~ 5.825 GHz

DJI INSPIRE 1 - The operation of the DJI INSPIRE 1 system

1. Build Materials - Carbon Fiber, Aluminum, Plastic & internal electrics

2. Motor Configuration - The DJI INSPIRE 1 has a quadcopter configuration

3. Payload - The DJI INSPIRE 1 flies its own light-weight integrated camera. Total weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, and/or chips.

Replace if propeller is questionable.

4. Check all wiring to motors, motor controllers, batteries, and flight controller.

5. Check all navigational lighting to ensure it is properly working.

II. after 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary.

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary.

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test 

flights before conducting commercial work.

DJI Phantom 3 - The operation of the DJI Phantom 3 system

1. Build Materials - Plastic, Aluminum and internal electrics.

2. Motor Configuration - The Phantom 3 has a quadcopter configuration.

3. Payload - The Phantom 3 its own integrated camera. Total Weight- 4lbs

4. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, and/or chips.

Replace if propeller is questionable.

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of

5. Check all navigational lighting to ensure it is properly working.

II. after 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary.
2. Remove motor controllers and visually inspect and check for damage. Replace as necessary.

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and

Perform a minimum of 15 test flights before conducting commercial work.

Appendix B – Flight Planning Prior to flight operations

1) Weather-Flight will require minimum weather of 200 feet above planned flight altitude and 

cloud clearance sufficient to see and avoid other aircraft. 

2) NOTAMS-Nearest airport NOTAMS and the nearest CLASS B Airspace will be checked to verify 

that there is nothing that would present a safety condition. 

3) TFR-Temporary Flight Restrictions will be checked and complied with using B4UFLY app.

4) Risk mitigation-Flight plan will be scrutinized to minimize risk and eliminate hazards to 

personnel and safety. Each aspect of the flight will require a detailed analysis and mitigation of 

risks associated with the operation of the UAS. 

5) Appendix C UAS Manuals

DJI user manuals and safety information can be obtained by accessing the following website:

http://www.dji.com/product/phantom-3-pro/info