# VS3 STUDIOS, LLC.

P .O. BOX 2893, WESTER VILLE, OH 43086 (740) 513

- 4899 | V S3STUDIOS@GMAIL.COM

PETITION FOR EXEMPTI ON

December 17, 2015

U.S. Department of Transportation

Federal Aviation Administration 800 Independence Avenue, SW

W ashington, DC 20591

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R.

, VS3 Studios, LLC , hereby applies for an exemption from the listed F ederal Aviation Regulations to allow commercial operation of it’s UAVs, so long as such operations are conducted

within and under the conditions outlined below or as may be established by the FAA as required by
Section 333.1

VS3 Studios, LLC

, has been in business since 2009 and has always stay ed up to date on technology

and to find ways to set apart our business from the competition

. As UAVs have become more popular

with the public, providing unique views at a far cheaper price than a traditional helicopter, our clients

, have started to request aerial still photography and videography shot from a UAV.

The exemption sought would allow VS3 Studios, LLC to provide aerial photography and videography to clients.

THE MAKE AND MODEL OF TH E AIRCRAFT FOR PROPO SED OPERATIONS

DJI Phantom 3 Standard

THE PROPOSED OPERATION S

P rovide aerial photography and videography to clients

HOW THE OPERATOR WIL L MAINTAIN AN EQUIVA LENT LEVEL OF SAFETY

As found in exemption No. 11138 (Trudeau), the FAA approved similar use of a DJI UAS. These devices were selected because they have proven reliable flying capabilities such as:

1. Has the ability to limit maximum altit ude2. G yro stabilized flig ht

3. G round detection

4. Limit the distance that the UAV will fly from the PIC

5. Limit the UAV from Class B, C and D airspaces

6. GPS aided navigation such as Naza

- M GPS & Compass unit enhance s performance for entry AP

with position hold, return

- to

- home and intelligent orientation control. With GP S Module, the

multi

- rotors will have position and altitude lo ck in windy conditions. Precise hovering in less than 2.5m horizontal and 0.8m vertical.

7. The Naza controller has built

- in auto level Fail

- Safe function. When communication between

the UAV and transmitter is d isconnected, the outputs of all command sticks from control ler will go to center point. If adequate GPS signal is available the UAV will automatically return to its launch point and land

8. Blinking LEDs

9. P ropeller guards

VS3 Studios, LLC

, w ill not fly in advers e weather conditions such as high winds or reduced visibility

and e nsure the operating environment is safe

.

SPECIFIC APPLICABLE REGULATIONS FROM WHICH RELIEF IS REQUIRED (CFRS)



### 14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operat ing area associated with the aircrafts to be utilized by VS3 Studios,
LLC , an exemption from Part 21 meets the require ments of an equivalent level of safety under Part 11 and Section 333 of the reform Act.



### 14 C.F.R. 45.23: Display of marks: general The UA does not have a cabin, cockpit, pilot station, fuse lage, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft.



### 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional manned airship experience of a commercial ly certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exempti ons to t his regulation through e xemption Nos. 11062 and 11138.



### 14 C.F.R 91.7: Civil aircraft airworthiness

T here is no certificate applicable to the U As in question, this regulation is inapplicable. However, VS3 Studios, LLC

, will r egister the UAS once the open registration process starts on December 21 , 2015

.



### 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator.



### 14 C.F.R. 91.119(c): Minimum safe altitudes VS3 Studios, LLC will ensure that our UAS will operates at approved altitudes

.

### 14 C.F.R. 91. 121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor . An equivalent level of safety will be achieved by using this.



### 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that VS3 Studios, LLC flies are powered by el ectricity, using lithium polymer batteries that currently have a flight limit of 30 minutes or less . Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151.



### 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

There are no procedures for providing air worthiness certificates for the mentioned UAS. VS3 Studios,
LLC , however will always fly safely while having the manual of the DJI Phantom 3 Standard. VS3 Studios, LLC will also register the UAS once the open registration process starts on December 21

, 2015

.

14 C.F.R. 91.405(

a): Maintenance Required

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or

A lteration

14 C.F.R. 91 .409(a)(1) and (2): Inspections

14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should b e granted since they only apply to aircraft with
an airworthiness certificate. However

, VS3 Studios, LLC

, w ill perform preflight inspections of the UAS before each flight as outlined in the operating documents.

HOW GRANTING THE EXE MPTION WOULD BE IN THE PUBL IC INTEREST

Aerial photography and videography as an availabl e service to the public allows for a less expensive method to capturing imagery than its alternative to using helicopters or airplanes to get similar views

. The helicopters and airplanes are expensive , creates signifi cantly more noise, and are more threatening

due to size, combustible fuel and a living crew on board.

In addition

, as ment ioned in the Trudeau exemption, No.11138: “ Manned aircraft conducting aerial filming and photography can weigh 5,000 l bs. or more, are operated by an onboard pilot and may carry

other onboard crew members, as well as 100 gallons or m ore of fuel. The petitioner’s [ UAS] weighs less than 3 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight re duces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a [ UAS] for the proposed operation.”

VS3 Studios, LLC respectfully requests exemption under Sec 333 to allow cost effective, efficient and safe operations of a UAV for gathering photographs and video

.