Todd Richard 

Synergy Productions, Inc.

PO Box 80225

Baton Rouge, LA 70898

May 21, 2015

U. S. Department of Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 

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

91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) 

and (b)

Dear FAA,

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

Part 11, Todd Richard, owner of Synergy Productions, inc., operator of an Unmanned Aircraft System 

(UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its UAS, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner: 

--Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other video production related professional activities. 

--Aerial video and/or photography for public and/or private use including television, cinematography for 

promotional presentations and news gathering. 

--Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

--Aerial inspection/photography of residential/commercial utility infrastructure including but not limited 

to electrical power lines, wind turbines and cell towers. 

--Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested it 

by contract or donation. 
As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” 

The name and address of the applicant is: 

Todd Richard/Pilot 

Synergy Productions, Inc.

PO Box 80225

Baton Rouge, LA 70898

Office # 225-927-5430

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 

CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 

CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

Synergy Productions, Inc. will operate the DJI Inspire 1 UAV, with a total weight of approximately 2935g

The dimensions are 438mm x 451mm x 301mm. Under still air the maximum speed is no more than 

50mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. The DJI Inspire 1 has four motors, powered by a 4500MAh Lithium Polymer battery. There 

is a single propeller for each of the four motors. The DJI Inspire 1 will be controlled with a remote 

controller with an operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an operating 

frequency of 5.728GHz – 5.850GHz. The applicant will operate the UAS in line of sight.

Given the small size of the UAS the proposed operations will adhere to the Reform Act’s safety 

requirements. The approval of this application presents no national security issues. Regarding the level of 

safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, 

including but not limited to reduced emissions and noise, the grant of the requested exemption is in the 

public interest. Accordingly the applicant requests that the FAA grant the requested exemption with 

minimum delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

The UAS will weigh less than 55 lbs. 

The UAS will have a maximum operating speed of no more than 50mph. 

Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 

Maximum flight time for each operational flight will be 18 minutes. Flights will be terminated at 25% 

battery power reserve or 10 minutes of flight time whichever occurs first. 

Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 

Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include 

but not limited to a Camera Operator. 

The UAS pilot will be a designated Pilot in Command (PIC). 

A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of 

all the days’ production activities. 

All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) 

of a tower controlled or uncontrolled airport. 

If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

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

with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 

48 hours from planned operation. 
The operator will obtain verbal/written consent of all persons involved with the planned operation and 

ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius 

may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the 

FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 

The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the 

particular UAS to be operated. 

The PIC and VO will be able to communicate by voice, and or radio. 

Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

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

emergencies. 

14 C.F.R. Part 2 1, Subpart H: Airworthiness Certificates 14 C.F.R. §91.20 (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 less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated 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. The FAA will have advance notice of all operations. These safety enhancements 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. 

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

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. Todd 

Richard/Synergy Productions, inc. may achieve an equivalent level of safety as achieved by current 

Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks 

attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to the safe 

operation of the UAS.

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 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 an equivalent level of safety will be provided.
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 pilot flying the UAS will 

have immediate access to it.

14 C.F.R. § 91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure 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 as stated in the FOM in Section 4 under Normal Procedures including 

but not limited to 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 91.103 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. UAS 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. The equivalent level of safety 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 ft. 

AGL, or not more than 200 ft. 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 ft. 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 200 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 55lbs. 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 addition, the low-altitude operations of the UAS 

will ensure separation between these 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 approximately 18 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 18 minutes 

in length. Given the limitations on the UAS’s 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 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the 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. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 

18 minutes or 25% 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.
14 C.F.R.c§91.203 (a) and (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.

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 section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight

manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very 

limited in size and will carry a small payload and operate only in restricted areas for a limited period of 

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

400 feet AGL. The operator 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 operator 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.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure 

that the UAS is in working order prior to initiating flight and perform required maintenance needed.
Additional Information

The applicant, Todd Richard, has been involved in the building and piloting of remote controlled aircraft 

for more than 1 year. Additionally the applicant, Todd Richard has many years experience shooting stills 

and Video from various aircraft since the late 1980’s. Fixed wing aircraft and all various Bell jet rangers, 

Hughes 500 and Airbus AS350 AStar helicopters have been utilized as platforms to shoot various aerial 

projects. This exposure and experience working with these aircraft and pilots that fly them have given the 

utmost respect for safety and professionalism while capturing top quaility images for clients.

Applicant humbly request a quick and speed review of section 333 exemption application.

Also, Aircraft registration application process has begun using aircraft tail number N157TR

Sincerely,

Todd Richard