Section 333 Exen1ption ]~equest 

Perspective Aerial Productions, LLC 

10/13/2015 

Perspective Aerial Productions, LLC 

Marsh, DavidS. 
Table of Contents 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Introduction, Exemption for Use of UAS for Business Applications 

Introduction, Exemption for Use of UAS for Business Applications ............................................................. 1 

UAS #1 DJIInspire 1 Quad ................................................................................................................ 4 

UAS #2 DJI Phantom 2 ...................................................................................................................... 4 

UAS #3 DJI S1000 Octocopter .......................................................................................................... 4 

I. Petitioner's Contact Information: .................................................................................................... 6 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which David Marsh 

Requests Exemption are: .......................................................................................................................... 7 

Ill. The Extent of relief David Marsh seeks and the Reason He Seeks Such Relief: .............................. 7 

IV. How David Marsh's Request Will Benefit the Public as a Whole: .................................................... 9 

V. Reasons Why David Marsh's Exemption Will Not Adversely Affect Safety or How the Exemption 

Will Provide a Level of Safety At least Equal to Existing Rule: ................................................................ 10 

VI. A Summary the FAA May Publish in the Federal Register: ............................................................ 11 

APPENDIX A ............................................................................................................................................. 15 

Sample Flight Screen with Live Data (Inspire 1 UAS) ............................................................ : ........ 15 

UAS #1 DJIInspire 1 Quad .............................................................................................................. 15 

APPENDIX 6 ............................................................................................................................................. 16 

Sample flight Screen with Live Data (DJI Phantom 2 Quad UAS) ................................................... 16 

UAS #2 DJI Phantom 2 .................................................................................................................... 16 

APPENDIX C ............................................................................................................................................. 17 

Sample flight Screen with Live Data (DJI S1000 Octocopter UAS) ................................................. 17 

UAS #3 DJI S1000 Octocopter ........................................................................................................ 17 

APPENDIX D ............................................................................................................................................. 18 

Operational Policies for all Unmanned Aircraft Systems ............................................................... 18 

APPENDIX E ............................................................................................................................................. 22 

DJIInspire 1 Operators Manual ..................................................................................................... 22 

Appendix F ............................................................................................................................................... 23 

DJI Phantom 2 Operators Manual .................................................................................................. 23 

Appendix G .............................................................................................................................................. 24 

DJI S1000 Operators Manual ......................................................................................................... 24 

Page 1 of 25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Perspective Aerial Productions, LLC 

PO Box 8178 

Williston, ND 58803 USA 

Email: info@PerspectiveAP.com Phone: 701.609.8334 

UAS Integration Office- Special Rules Coordinator 

Federal Aviation Administration 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Ave., SE, 

Washington, DC 20590 

RE: Introduction, Exemption for Use of UAS for Business Applications 

October 13, 2015 

To whom it may concern: 

I, David Marsh, dba "Perspective Aerial Productions, LLC," 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 I, David Marsh, am owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (FARs) listed below so that I, David Marsh, may operate my small ultralight weight 

unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA). 

As described herein I, David Marsh, am a licensed commercial pilot, certificate number: 3319982, having 

obtained my certificate in 1994. I am experienced in flying hobby aircraft for recreational purposes and 

have been flying RC fixed wing and rotor aircraft since I have 2010. I have added two state-of-art 

professional grade quad-copter UAS vehicles from well-known manufacturer (DJI) to my inventory 

equipped with factory installed high resolution gimbaled camera systems with intent for aerial photos, 

videography/cinematography. I have also added a state of the art professional grade octocopter from 

the same manufacturer (DJI) with a gimbaled camera for aerial photos, videography/cinematography. 

The purpose of these equipment additions will be to enhance academic community awareness for 

those individuals and companies unfamiliar with UAVs in the geographical layout of the areas I serve, 

to provide small businesses and individuals with video production services targeting marketing, 

construction progress, tower inspection, insurance assessments, real estate, search and rescue, event 

videography including but limited to wedding, sports, public/private events, weather, etc., following 

the exemption and approval for my operations while also reducing risk and liability from manned 

aircraft alternatives. 

Page 2 of 25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

I am also a member of the AMA, Academy of Model Aeronautics, and have flown small radio controlled 

(RC) electric aircraft for over five (5) years without incident. I have been flying RC gasoline powered fixed 

wing aircraft since 2010, also without incident. Committed to safety with each flight, my exemption 

request would permit operation of light weight, unmanned (piloted by remote control) and 

comparatively inexpensive UAS(s) in areas away from general public, airports, heliports, and vehicular 

traffic. My general purpose for the use of the UAS will be to produce community videos; videos of 

commercial, industrial, and residential properties for sale or rent and within property boundaries for 

individual homeowner, insurance assessments, real estate listing videos/photos; small business videos; 

construction progress and tower inspection; and event videography including by not limited to wedding, 

sports, public/private parties, etc. Currently, similar lightweight, remote controlled UASs are legally 

operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent 

catastrophe. I have personally designed and implemented safety protocols and controls to prevent 

public hazard and mitigate risk significantly over the alternative manned aircraft hazards/catastrophe. In 

addition, services performed by the UAS will allow for video which cannot be safely shot from 

conventional manned aircraft alternatives. 

Additionally, I will notify any persons present in the operational area by posting temporary safety signs 

notifying all persons that aerial drone videography operations are taking place and to be alert to the 

presence of the UAS aircraft. Signs will be posted up to 30 minutes before flight operations and continue 

until all UAS operations are concluded at each site. This will act to further safety protocols exclusive to 

lightweight UAS's specific to video and photography usage as I, David Marsh, record flight data and 

other information gained through permitted flight operations to share with the FAA through any 

required FAA reports to assist with future protocol and safety regulation 

Granting my, David Marsh, request comports with the Secretary ofTransportations (FAA Administrators) 

responsibilities and authority to not only integrate UAS's into the national airspace system, but to also 

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 and other small business applications. Further I will conduct my operations in compliance with 

the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below I, David Marsh, respectfully request the grant of an exemption allowing me 

to operate ultra-light weight, remote controlled UASs for academic community awareness to 

benefit/stimulate attraction to the areas of operation in the United States and its surrounding 

communities to enhance videos for businesses and private individuals who cannot afford expensive, 

high-risk manned aircraft for the same purpose. My activities will promote local economic growth 

through increased employment and increased tax base, the provision of new services and enhancement 

of producing a more efficient and more comprehensive photographic and cinematography system, 

allowing consumers to better determine the value of the specific projects using enhanced online video 

capabilities. Furthermore, by using my UAS system as an alternative to heavier manned aircraft 

containing combustible fuel that poses potential public hazard, I will also be contributing to the safety of 

the local communities served. 

Page 3 of 25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

I have attached detailed information on the three UAS proposed. The following is a short summary of 

each system: 

UAS #1 Djllnspire 1 Quad 

Manufacturer: DJI 

Model: Inspire 1 T600 

Weight: 2935 g I 6.47 Pounds 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 438x451x301 mm (17.24x17.76x11.85 inches) 

Max Speed: 22 mps (72.18 fps I 49.21 mph) 

Max Flight Time: 18-25 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance 

UAS #Z DJI Phantom 2 

Manufacturer: DJI 

Model: Phantom 2 

Weight: 1000 g I 2.2 Pounds 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 406.4x406.4x203.2mm(16x16x8 inches) 

Max Speed: 15 mps (49.12 fps I 33.55mph) 

Max FlightTime: 18-25 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 1 maximum rated operating distance 

UAS #3 DJI S1000 Octocopter 

Manufacturer: DJI 

Model: Spreading Wings 51000 

Weight: 4.2 kg (9.26 pounds) 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 1093.5x1093.5x610mm (43.05x43.05x24 inches) 

Max Speed: 22 mps (72.18 fps I 49.21 mph) 

Max Flight Time: -30 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance 

Page 4 of25 
Specifically, each UAS is: 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

A lightweight(< 25 lb gross weight with all on-board equipment), battery operated 4- motor rotorcraft in 

the form of a quadcopter or octocopter that takes off and lands vertically, manufactured by DJI, each 

with the following equipment: 

-An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller; 

-An on-board camera capable of capturing imagery in the form of full color, high definition still 

photos and video; 

-An on-board telemetry system that delivers flight data from the on-board flight computer to 

the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site; 

-An integrated 5.8GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above. 

The Ground Station Includes: 

- A Pilot in Command (PIC) in operational control of a flight operation from beginning to end 

and who controls the UAS while in the air; 

-A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in 

flight; 

-A radio receiver receiving live video and flight data from the on-board camera and computer 

projects it all together onto a screen for the PIC to view during flight. 

Thank you for reviewing my request 

David Marsh 

Perspective Aerial Productions, LLC 

Commercial Pilot, Drone Pilot 

Page 5 of 25 

David Marsh 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS , 

Under Section 333, Title 14 

Perspective Aerial Productions, LLC 

PO Box 8178 

Williston, ND 58803 USA 

Email: info@PerspectiveAP.com Phone: 701.609.8334 

UAS Integration Office- Special Rules Coordinator 

Federal Aviation Administration 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Ave., SE, 

Washington, DC 20590 

RE: Introduction, Exemption for Use ofUAS for Business Applications 

October 13, 2015 

To whom it may concern: 

I, David Marsh, dba "Perspective Aerial Productions, LLC," 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 I, David Marsh, am owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (FARs) listed below so that I, David Marsh, may operate my small ultralight weight 

unmanned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA). 

As described herein I, David Marsh, am a licensed commercial pilot, certificate number: 3319982, having 

obtained my certificate in 1994. I am experienced in flying hobby aircraft for recreational purposes and 

have been flying RC fixed wing and rotor aircraft since I have 2010. I have added two state-of-art 

professional grade quad-copter UAS vehicles from well-known manufacturer (DJI) to my inventory 

equipped with factory installed high resolution gimbaled camera systems with intent for aerial photos, 

videography/cinematography. I have also ~dded a state of the art professional grade octocopter from 

the same manufacturer (DJI) with a gimbaled camera for aerial photos, videography/cinematography. 

The purpose of these equipment additions will be to enhance academic community awareness for 

those individuals and companies unfamiliar with UAVs in the geographical layout of the areas I serve, 

to provide small businesses and individuals with video production services targeting marketing, 

construction progress, tower inspection, insurance assessments, real estate, search and rescue, event 

videography including but limited to wedding, sports, public/private events, weather, etc., following 

the exemption and approval for my operations while also reducing risk and liability from manned 

aircraft alternatives. 

Page 2 of25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From 

Which David Marsh Requests Exemption are: 

14CFR 21; 14CFR 45.23(b); 14CFR 61.113(a)&(b); 14CFR 91, et seq.; 

14CFR 407(a)(1); 14CFR 409{a)(2); and 14CFR 417(a)&(b). 

III. The Extent of relief David Marsh seeks and the Reason He Seeks Such Relief: 

Page 7 of25 

I, David Marsh, am a licensed Private Pilot, certificate number 3319982, having obtained my 

license in 1995. 

I, David Marsh, submit this application in accordance with the Reform Act, 112PL 95§§ 331-

334, seeking relief from any currently applicable FARs operating to prevent me, David 

Marsh, contemplated commercial cinematic, academic and other flight operations within 

the national airspace system. 

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. David 

Marsh's ultra-light weight UAS is expressly contemplated by the Reform Act. I would like to 

operate my ultra-light weight UAS prior to the time period by which the Reform Act requires 

the FAA to promulgate. rules governing such craft. Thereby, providing direct experience and 

valuable information for formal regulation that can be administered uniformly to all real 

estate related UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS's that may operate 

safely in our national airspace system. Considerations include: The weight, size, speed, and 

overall capabilities of the UAS's; whether the UAS will be operated near airports or heavily 

populated areas; and, whether the UAS will be operated by line of sight. 112PL 95 § 333{a). 

Each of these items reflects in favor of an exemption for me. My UAS aircraft utilize four (4) 

or eight (8) counter-rotating propellers for balance, control and stability. My UA's are 

equipped with GPS and auto return safety technology. My UA Maximum Takeoff Weight is 

less than twenty-five (25) pounds (far below the maximum 55 pounds limit); including 

camera with gimbal and any other payload. Each would be classified as an ultra-light UAS 

aircraft. 

I consider safety as foremost with each flight. My small unmanned aircraft are designed to 

hover in place via GPS and operate in less than a 24 knot (20.8 mph) wind. For safety, 

stability and fear of financial loss, I will not fly in winds exceeding24 kph (20.8 mph). Built in 

safety systems include a GPS mode that allows my UAS to hover in place when radio controls 

are released. With three modes to choose from, I utilize the Smart Mode* (See 

manufacturer's Operating Manual) for aerial videography/photography. This is the safest, 

most reliable and stable mode to prevent accident and hazard. When pilot communication 

is lost the UA is designed slowly return and descend to point of takeoff. I do not operate my 

UAS near airports, hospital or police heliports, and do not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions, and 

weather. 
Page 8 of 25 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Horizontal Ground Speed for most drone videography requirements are typically less than 7-

10 miles per hour which further adds to safety. Maneuvers are limited in scope and gently 

performed (as opposed to more radical recreational use) due to the need to keep the 

camera steady for video purposes. Flight paths are planned out in advance, as opposed to 

recreational flight and therefore safer than many recreational flights since speed, 

maneuvers and flight paths are very conservative and preplanned. 

During any planned operation of the UAS, I first scout the area and flight path; determine 

what obstacles, if any, are present, where to post warning signs notifying persons that aerial 

drone photography is taking place and any other conditions from lighting, line of sight issues 

and power lines that I should be aware of to conduct safe operations. I clearly mark the area 

of the flight path with warning signs indicating that the UAS will be in operation 30 minutes 

prior to the flight and until all flight operations have ceased. 

I maintain a second observer at all times who remains within 10 yards of the PIC position 

and who is responsible for spotting obstacles, people, vehicles, and manned aircraft, as well 

as keeping track of the UAS position. 

I am constantly alert for any manned aircraft (Police/Medical helicopters, private and 

commercial aircraft of any type, model aircraft, etc.) and prepared to land/abort 

immediately to the nearest and safest ground point should a manned aircraft approach my 

location or I suspect manned aircraft may approach near my location. My UAS is capable of 

vertical and horizontal operations, and are flown only within my line of sight, as the remote 

control pilot (PIC). 

Utilizing battery power rather than combustible fuels, flights generally last between three 

{3) to fifteen (15) minutes, with an altitude under 400 feet. I utilize a fresh fully charged 

battery with each flight as a safety precaution; full flight time limit for each battery is 

eighteen (18) to twenty-five (25) minutes as specified by the manufacturers and consistently 

twenty-one (21) to twenty-five (25 minutes as tested. 

My flight equipment provides for the monitoring of battery levels during flight. I do not 

operate my UAS at or below manufacture recommended minimum charge levels for 

operation; preferring to remain well within a safe operating range to insure adequate 

communication between radio control and UAS to eliminate potential for crash, loss of 

control or hazard. Reserve batteries are on hand with each event to insure replacement for 

a sufficient safe level of operation. I do not believe in taking risks that may cause a crash, 

that could create a hazard to the public, public or private property, or manned aircraft and 

have no desire to lose my very substantial investment in my UAS equipment. 

As of this time, I have completed over 200 practice flights with over 40 hours of UAS 

airborne operations as a hobbyist simulated fights for future commercial use to gain 

familiarization with the characteristics of my specific UAS models' operations and 

performance under different temperature and weather conditions. I also practice regular 

weekly computerized simulated flights to maintain adequate skills and response reflex time, 

all this for the sake of safety. I have no less than (5) five hours of flight time logged in each 

model proposed herein within the past 90 day period. 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

I, David Marsh, am extremely cautious when operating my UAS/ultra-light weight aircraft 

and will not "create a hazard to users of the national airspace system or the public." 112PL 

95§ 333(b). Given the small size and weight of my UAS it falls well within Congress's 

contemplated safety zone when it promulgated the Reform Act and the corresponding 

directive to integrate UAS's into the national airspace system. David Marsh's UASs, used in 

hobby flight, has a demonstrated safety record and does not pose any threat to the general 

public or national security. The UAS aircraft used are modern model units manufactured by 

leading manufacturers (brand names) in the industry: DJI. They have extensive experience in 

Unmanned Aerial Video flight Systems and provide extensive software, flight manuals, 

operational information, specifications, and customer support on their products. 

IV. How David Marsh's Request Will Benefit the Public as a Whole: 

Aerial videography for geographical awareness and for real estate marketing has been around for a 

long time through manned fixed wing aircraft and helicopters. For small budget real estate 

companies and average homeowners the expense of such aerial videography is cost prohibitive. Only 

large companies and high-end realtors or luxury homeowners can afford to absorb such expense, 

depriving non-luxury homeowners and lower budget realtors from a valuable marketing tool. 

Manned aircraft pose a threat to the public through potential catastrophic crash, each having the 

potential result of loss of life, damage to property and substantial cost involved in responding to, 

handling the emergency and the subsequent investigation and clean up. Each such manned aircraft 

event also involves combustible fuel that in the Past has exploded and burned on impact. Police 

helicopters have made emergency hard landings within city limits. My, David Marsh's, UAS pose no 

such threat since size and lack of combustible fuel alleviates almost all potential threat to the public. 

Congress has already proclaimed that it is in the public's interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, David 

Marsh's, exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits in and around the United States. My ultra-light UAS is battery powered and 

creates no emissions that can harm the environment. The consequence of my ultra-light weight UAS 

crashing is far less than a full sized helicopter or fixed wing aircraft; which are manned, heavy, 

contain combustible fuel and can cause catastrophic devastation to the public. 

The public's interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated ultra-light UAS's. Permitting me, David Marsh, to 

immediately fly within national air space furthers economic growth. Granting my exemption request 

substantially furthers the economic impact for the North Dakota and surrounding communities and 

cities for companies looking to relocate for career advancement through academic and geographical 

awareness; both of which serve as a stimulus to the communities involved. 

Page 9 of 25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

V. Reasons Why David Marsh's Exemption Will Not Adversely Affect Safety or 

How the Exemption Will Provide a Level of Safety At least Equal to Existing 

Rule: 

My, David Marsh's, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated, permitting me, David Marsh, to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow me to contribute to the innovation and implementation of 

new and novel, as of yet undiscovered safety protocols for realtors that can be embraced by the 

NAR, AAR, and TAR for development in cooperation with the FAA, In addition I, David Marsh, submit 

the following representations of enhancements to current aerial videography and photography for 

real estate: 

My UAS aircraft weigh less than 25 pounds complete with a small ultra-lightweight high quality 

factory installed gimbaled high definition camera; I only operate my UAS below 400 feet (within in 

the 400 foot permissible ceiling set by the FAA Modernization and Reform·Act of2012); my UAS only 

operates for 3-15 minutes average per flight; I land my UAS significantly prior to manufacturer 

recommended minimum level of battery power which my flight systems monitor throughout the 

flight; I pilot my UAS through remote control only by line of sight; My UAS has GPS a flight safety 

feature whereby it hovers and then returns to the point of takeoff. Then slowly lands if 

communication with the remote control pilot is lost; I actively analyze flight data and other sources 

of information to constantly update and enhance safety protocols; I only operate in reasonably safe 

environment that are strictly controlled, are away from power lines, elevated lights, airports, and 

actively populated areas; I conduct extensive pre-flight inspections and protocol according to all 

manufacturers recommendations as well as that of the AMA (Academy of Model Aeronautics), 

during which safety carries primary importance; I always obtain all necessary permissions prior to 

operation; and , I have procedures in place to abort flights in the event of safety breaches or any 

potential danger. 

My, David Marsh's, safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial UAS into our _nation airspace system, 

helicopters are the primary means of aerial video and photography for community awareness and 

real estate While the safety record of such helicopters is remarkably astounding there have been 

incidents involving loss of life as well as extensive property damage; it is far safer to operate a 

battery powered ultra-light weight UAS. 

Page 10 of25 

First, the potential loss of life is diminished because UAS's carry no people on board and I 

only operate my UAS in specific areas away from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. 

Third, the small size and extreme maneuverability of my UAS allows me to remotely pilot 

away from the avoidable hazards quickly and safely. 

Lastly, given its small size and weight, even when close enough to capture amazing images, 

my UAS need not be so close to the objects they are focused on through the technology and 

use of post editing software allowing pan, tilt, and zoom. 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Accordingly, my UAS has been experimentally operated for familiarization/competency and will 

continue to operate at and above current safety levels. 

VI. A Summary the FAA May Publish in the Federal Register: 

A. 14CFR 21 and 14CFR 91: Airworthiness Certificates, Manuals, and Similar. 

14 CFR 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§91.203(a)(1). The size, 

weight, and enclosed operational area of my UAS aircrafts permit exemption from Part 21 

because my UAS aircrafts meet (and exceed) an equivalent level of safety pursuant to Section 

333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 USC§44701(f)) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. My current and projected UAS's meet or exceed each of 

the elements. 

14 CFR § 91. 7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR § 91.9 (b) (2) requires an aircraft fight manual in the aircraft. As there are no on-board 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

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

areas of where safety can be defined. The FAA has previously issued exemption to this regulation 

in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9656B, 10167, 10167 A, 10602, 10700, 

and 32827. 

14 CFR § 91.121 regarding altimeter setting is inapplicable insofar as my UAS utilizes electronic 

global positioning systems with a barometric sensor. 

14 CFR § 91.203(a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by me 

and any proposed PICs of the UAS proposed. 

14 CFR § 45.23: Marking of the Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications My UASs are, by definition, unmanned. They therefore do not have a cabin, 

cockpit, or pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft with dimensions smaller than minimal lettering 

requirement. 

Page 11 of25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Regardless, I propose that each UA will carry its appropriate "N" number if one is issued by the 

FAA, in such size as can reasonably fit upon the sides of the aircraft in at least two locations on 

the booms or fuselage. If an "N" number is not obtained from the FAA, I will mark the related 

UAS in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as 

required by 14 CFR § 45.29(f) so that I, the pilot, or anyone assisting me as a spotter with the UA 

will see the markings. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167 A, and 10700. 

14 CFR § 61.113: Private Pilot Privileges and Limitations: PIC 

Pursuant to 14 CFR §§ 61.113(a) & (b), private pilots are limited to non-commercial operations. 

The FAA has previously ruled in its exemption that a Private Pilot's Certificate is required for 

flight of the UAS for commercial purposes. I, David Marsh, am a licensed commercial pilot and 

will assure that all PIC's proposed to operate any of the UAS aircraft also have at minimum a 

Private Pilot's certificate and current Class Three medical. 

My UAS's do not carry any pilots or passengers. The risks attended to the operation of my UAS is 

far less than the risk levels inherent in the commercial activities outlines in 14 CFR § 61, et seq. 

Thus, allowing me and any other Private Pilot certified PIC to operate the proposed UAS's to 

meet and exceed current safety levels in relations to 14 CFR § 61.133(a)&(b). 

14 CFR 91.119: Minimum Safe Altitudes. 

14 CFR 91.119 p,rescribes safe altitudes for the operation of civil aircraft. It allows helicopters to 

operate at lower altitudes in certain conditions. My UAS will never operate at an altitude at 

greater than 400 AGL; the safety standard set by FAA. I will however operate my UAS's in safe 

areas away from public and traffic, providing a level of safety at least equivalent to or below 

those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed 

of my UAS, an equivalent or higher level of safety will be achieved. 

14 CFR 91.40S(a); 497(a)(1); 409(a)(2); 417(a)&(b): Maintenance Inspections 

The above-cited Regulation require, amongst other things, aircraft owners and operators to 

"have [the] aircraft inspected and prescribed in Subpart E of this part and shall between required 

inspection, except as provided in paragraph ( c ) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter ... " 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my proposed UAS's. However, as safety precaution I require the PIC to 

perform a comprehensive pre-flight and post-flight inspection of the UAS, adhering to the 

manufacturers' recommendations and checking all flight systems, power systems, rotors, and 

electronics including battery levels. The UAS has significant self-diagnostic software and systems 

checks built into its operations. Any system not reporting correctly and fully functional shall 

result in an aborted flight until the problem is identified and solved and the systems once again 

report 100% functional and operational. 

A Summary the FAA My Publish in the Federal Register: A. 14 CFR 21 and 14 CFR 91: 

Airworthiness Certificates, Manuals, and similar. 14 CFR 21, Subpart H, entitled Airworthiness 

Certificates, sets forth requirements for procurement of necessary airworthiness certificates fn 

Page 12 of 25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

relations to FAR § 9J..203(a)(1). The size, weight, and enclosed operational area of my UAS's 

permits exemption from Part 21 because my proposed UAS's meets an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft form the 

airworthiness certificate requirement under both the Act (49 USC§ 44701(f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My UAS's both 

meets or exceeds each of the elements. 

14 CFR 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 14 CFR § 91.19(b)(2) requires an aircraft flight manual in the aircraft. As there are 

no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, maintenance program that involves regular software updates and curative 

measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. 

In summary, David Marsh seeks an exemption from the following Regulations: 

14CFR 21, subpart H; 14CFR 45.23(b); 14CFR §§ 61.113(a)&(b); 14CFR § 91.7(a); 14CFR § 91.9 (b) 

(2); 14CFR 91.103(b); 14CFR 91.109; 14CFR § 91.119; 14CFR § 91.121; 14CFR § 91.151(a); 14CFR 

§§91.203(a) and (b); 14CFR § 91.405(a); 14CFR § 91.407(a)(1); 14CFR §91.409(a)(2); and 14CFR 

§91.417(a)&(b) to commercially operate my three small, ultra-light weight, unmanned aircraft 

vehicles (UAV's) to community awareness for the public good and for real estate to enhance 

operations and small business operations, to develop economic platforms for real estate to 

enhance the experience of those seeking to relocate to any such area served. 

Currently, area awareness and real estate aerial videography/photography relies primarily on 

the use of larger aircraft running on combustible fuel, posing potential risk to the public. 

Granting my request for exemption will reduce current risk level and thereby enhance safety. 

My UAS aircraft do not contain potentially explosive fuel. They are far smaller, lighter, and more 

maneuverable than conventional real estate video and photographic aircraft with much less 

flight time and do not require transit to and from the "shoot" location to an airport, resulting in 

far less required time airborne and therefore exposure & Liability. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from 

established airports and operations take place well below pattern altitudes. All of my operations 

are conducted with a pre-flight aircraft inspection, flight path inspection, and actual flights are 

normally conducted at very low altitudes and speed with conservative maneuvers necessary for 

video cinematography. 

I, David Marsh, have been informally analyzing flight information and will compile safety 

protocols and implementation of a flight operations manual for real estate and similar small 

business usage that exceeds currently accepted means and methods for safe flight. Formal 

collection of information shared with the FAA will enhance the FAA's internal efforts to establish 

protocols for complying with the FAA Modernization and Reform Act of 2012. 

Page 13 of25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

There are no personnel on board my UAS and therefore the likelihood of death or serious bodily 

injury is significantly diminished. My operation of UAS's, weighing less than twenty-five (25) 

pounds and travelling at far lower speeds within limited areas will provide an equivalent level of 

safety as that achieved under current FI>.Rs. 

Accordingly, I respectfully request that the FAA grant my exemption request and am willing to cooperate in 

sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. 

"""""' ~d, 

David Marsh 

Commercial Pilot 

UAS Pilot in Command, 

Cinematographer 

Page 14 of25 
APPENDIX A 

Sample Flight Screen with Live Data (Inspire 1 UAS) 

Specifications Overview 

UAS #1 DJI Inspire 1 Quad 

Manufacturer: DJI 

Model: Inspire 1 T600 

Weight: 2935 g I 6.47 Pounds 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 438x451x301 mm (17.24xl7.76x11.85 inches) 

Max Speed: 22 mps (72.18 fps I 49.21 mph) 

Max Flight Time: 18-25 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance 

Page 15 of 25 
APPENDIX B 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Sample flight Screen with Live Data (DJI Phantom 2 Quad UAS) 

Specifications Overview 

UAS #2 Djl Phantom 2 

Manufacturer: DJI 

Model: Phantom 2 

Weight: 1000 g I 2.2 Pounds 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 406.4x406.4x203.2mm(16x16x8 inches) 

Max Speed: 15 mps (49.12 fps I 33.55mph) 

Max Flight Time: 18-25 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 1 maximum rated operating distance 

Page 16 of 25 
APPENDIX C 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Sample flight Screen with Live Data (D)J SlOOO Octocopter UAS) 

Specifications Overview 

UAS #3 DJI S1000 Octocopter 

Manufacturer: DJI 

Model: Spreading Wings S1000 

Weight: 4.2 kg (9.26 pounds) 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 1093.5x1093.5x610mm (43.05x43.05x24 inches) 

Max Speed: 22 mps (72.18 fps I 49.21 mph) 

Max Flight Time: N30 mins 

Max Ceiling (software limited): 400ft AGL 

Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance 

Page 17 of 25 
APPENDIX D 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

Operational Policies for all Unmanned Aircraft Systems 

Perspective Aerial Productions, LLC 

David Marsh 

1. The unmanned aircraft system (UAS) will weigh less than 25 pounds, including energy source(s) 

and equipment and shall not be loaded with any unauthorized payloads. 

2. The UAS will not be flown at a ground speed exceeding 35 mph. 

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator's manual. All altitudes reported to ATC 

muST be in feet AGL. 

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses. 

5. All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to 

communicate verbally at all times. 

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a conditional for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. All maintenance and alterations will be properly 

documented in the aircraft records. 

Pre-Flight Protocol: 

1. Check batteries to insure fully charged and ready for use. Inspect batteries for damage or leakage 

that may affect proper operation. 

2. Inspect propellers for cracks, chips, or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

3. Check weather forecasts for wind advisory or other conditions that may impact flight. Consult five (5) 

mile radius for airport vicinity. 

4. Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information as may be required by distance. 

a. Inspect flight area for: 

Page 18 of 25 

i. Vicinity of public safety helipads/heliports 

ii. Vicinity of medical helipads/heliports 

iii. Vicinity of light poles 

iv. Vicinity of utility wires 

v. Vicinity of trees or any other obstacles 

vi. Flocks of birds that may cause interference and potential flight impact 

vii. Vicinity of any elevated obstruction that may pose potential flight hazard 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

viii. Vicinity of roadways with moderate to heavy traffic that can be distracting 

/distracted. 

ix. Public gatherings that may attract viewers 

x. Optional point of control for best visual site of UAS while in flight, takeoff, and 

landing 

b. Inspect area for best and safest point of takeoff and landing 

5. If in a subdivision or area that is within 150 feet of a residential street, post warning sign(s)/stand(s): 

Attention Aerial Photography in Progress- Stay Back 150 Feet" 

Flight Protocol: 

Takeoff and land from same location whenever possible. 

1. Remain alert to birds, sound or aircraft, curious public, and approaching vehicles. 

2. Do not allow anyone to engage in conversation or distract the remote control Pilot (PIC) restrict flight 

to minimal elevation sufficient to acquire desired results. 

3. Remain prepared for emergency landing at all times; pay attention to flight time. 

4. If possible set a timer as a safety alert. 

5. Land UAS and shut down propulsion immediately following landing. 

Post Flight Protocol: 

1. Disconnect battery to prevent accidental activation or propulsion system 

2. Secure UAS in a safe location 

3. Remove all warning signs from public access areas 

Emergency or Suspected Hazard Protocol: 

Immediately land UAS at safest and closest location in the event: 

• Manned aircraft is heard or seen in vicinity of flight. 

• There is a public gathering within established safety boundary wanting to observe flight. 

• Pilot is being distracted from focusing on flight and safety 

• Sudden change in weather (wind bursts) 

• Sudden increase in vehicular traffic in vicinity of flight 

• Birds enter into proximity of flight 

7. If the UAS has undergone 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 in 

accordance with the operator's manual. The PIC who conducts the functional test flight will make an 

entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test 

flight and aircraft record entry will be added to the operator's manual. 

8. The operator will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirement will be 

Page 19 of25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

established and identified in the operator's manual. At a minimum, requirements for the following 

will be included in the operator's manual: 

a. Actuators/Servos; 

b. Transmission (single rotor) 

c. Power Plants (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

i. Ground control station (if used); and 

j. Any other components as determined by the operator. 

9. The Pilot In Command (PIC} will possess at least a private pilot certificate and current third class 

medical certificate and at least a valid driver's license. 

10. Prior to operations the PIC will have accumulated and logged, in a manner of consistent with 14 CFR 

§61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at 

least ten hours logged as a UAS pilot with a similar UAS type (single blade or multi rotor). Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted 

to accomplish the required flight cycles and flight time. 

11. Prior to operations the Pic will have accumulated and logged, in a manner consistent with 14CFR§a 

minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for 

operations and three take-offs and three landings in the preceding 90 days. Training, proficiency, 

experience-building, and take-off and landing currency flights can be conducted to accomplish the 

required flight cycles and flight time. 

12. The UAS may not be operated directly over any person, except authorized and consenting personnel, 

below an altitude that is hazardous to persons or property on the surface in the event of a UAS 

failure or emergency. 

13. The operator will request all non-authorized and consenting persons to remain clear of the 

operational area by not less than 100 feet. 

14. The UAS will abort the fight in the event of unpredicted obstacles or emergencies in accordance with 

the operator's manual. 

15. Each UAS operation will be completed within 15 minutes maximum flight time or with 25% battery 

power remaining, whichever occurs first. 

16. If the operational area is within 5 miles of any airport, the PIC will obtain an Air Traffic Organization 

(ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations. This 

COA will also require the operator to request a Notice of Airman (NOT AM) not more than 72 hours in 

advance, but not less than 48 hours prior to operation. 

17. All aircraft operated in accordance will be identified by serial number, registered in accordance with 

14CFR part 47, and have identification (N-Number) markings in accordance with 14CFR part 45 

subpart C. Markings must be as large as practicable. If this registration is not available from the FAA, 

then each such aircraft shall be marked "Experimental." 

18. Each UAS operated will comply with all manufacturer Safety Bulletins. 

19. The radio frequency spectrum used for operation and control of the UAV will comply with the 

Federal Communications Commission (FDD) or other appropriate government oversight agency 

requirements. 

20. If operating within five (5) miles of the center of any airport, at least three days before scheduled 

flight, the PIC or operator will submit a written Plan of Activities to the local FSDO with jurisdiction 

Page 20 of25 
David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 14 

over the area of proposed flight area. The 3-day notification may be waived with the concurrence of 

the FSDO. The plan of activities must include the following: 

a. Date and times for all flights; 

b. Name and phone number of the operator; 

c. Make, model, and serial or N-number of US to be used; 

d. Name and certificate number of UAS PIC involved; 

e. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the flight operations; the list of those who gave permission must be 

made available to the inspector upon request; 

f. Signature of exemption-holder or representative; 

g. A description of the flight activity, including maps, diagrams of any area, city, town, county, 

and/or state over which the flights will be conducted and the altitudes essential to 

accomplish the operation. 

21. The documents required under 14CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground 

control Station of the UAS any time the aircraft is operating 

22. The UA will remain clear and yield the right of way to all other manned operations and activities at 

all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, 

hang gliders, etc.). 

23. UAS operations will not be conducted during night, as defined in 14CFR §1.1. All operations will be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR) are not authorized. 

24. The UAS 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. 

25. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS 

may not operate within 5 nautical miles of the geographic center of a non-towered airport as 

denoted on a current FAA-published aeronautical char unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a NOT AM as 

required by the operator's COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request. 

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational areas as defined by the applicable COA will be reported to the FAA's UAS Integration 

Office (AFS-80) within 24 hours. 

Page 21 of25 
APPENDIX E 

DJI fnspire 1 Operators Manual 

(See Separate Attachment) 

File: DJIInspire Operations Manual 

Inspire 1 User Manual v1.2 en.pdf 

Page 22 of25 

David Marsh 

Perspective Aerial Productions, LLC 

Request for Exemption for Use of UAS 

Under Section 333, Title 1.4