January 15, 2016 

Federal Aviation Administration (FAA) 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

Dear Sir or Ma’am: 

This petition is being submitted on our behalf without legal counsel or counseling services. Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 

Gifted Studio, LLC., a photographic and gift business (GS), hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft 

Systems (sUAS) commercially in airspace regulated by the FAA so long as such operations are conducted 

with and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

The requested exemption would permit GS to pursue its commercial interests in providing aerial data 

capture to clients using a small advanced sUAV in the following areas: 

- Real Estate 

- Marketing 

- Mapping 

- Surveying 

- Special Events 

- Agriculture 

- Inspection 

- General Photography 

Regulations from which exemption is requested: 

14 C.F.R. Part 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. 91.109 

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. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 – 91.417 
Gifted Studio, LLC. is co-owned by Theodore L. Johnson and Melissa S. Johnson. Mr. and Mrs. Johnson 

are both involved in the agricultural industry in Iowa. Mr. Johnson also holds a Private Pilot certificate. 

The company intends to use a DJI Phantom III for aerial photography. This will serve to improve farm 

efficiency by allowing visual observation of crop progress. Real estate photography and inspection 

photography will also be more efficient and safer as using an sUAV avoids the high risks in a helicopter 

and/or fixed wing aircraft with fuel and persons on board. The reduced noise and size creates a much 

smaller environmental impact which promotes public and environmental safety. 

To make sure the operation will be safely conducted, TGS will ensure that the PIC for all operations 

holds a sport, private, or commercial pilot certificate, and uses a Visual Observer (VO) at all times. The 

PIC and VO will survey the flight area for any mobile phone base stations, radio transmission towers, 

power lines, or any other electromagnetic interference that could disrupt flight. The PIC and observer

will scan the area for any large buildings or trees that may affect with GPS accuracy or flight. Both PIC 

and Observer will verify the weather is safe for flight to avoid wind speed exceeding 10 m/s, snowfall, 

rainfall, and restricted environmental visibility. Additionally, the PIC and Observer will go through the 

PREFILGHT CHECKLIST/maintenance and FLIGHT TEST PROCEEDURES in a secure area safe from persons 

and property. 

The DJI Phantom 3 Professional is equipped with a built-in stabilized HD camera and GPS safety features. 

These safety features include the ability to restrict the maximum altitude they operate above ground 

level (AGL), to limit the radial distance from the operator and to exclude them from operations within

designated Class B, C and D airspace including “no-fly zones”. This model has a failsafe function that is 

automatically engaged in the event communication is lost between the sUAS and the main controller 

transmitter. At that time, the sUAS will return to its point of takeoff and land safely. If the connection is 

restored, the PIC can regain control of flight and land manually. 

These specifications meet or exceed the Model Aircraft Operating Standards as set below: 

- The petitioner will only operate its sUAS in line-of-sight of a PIC and/or Observer and will operate at 

sites that are “sufficient distance” from populated areas within the sterile area described in the FOPM. 

Such operations will ensure the sUAS will “not create a hazard to users of the national airspace system 

or the public.” 

- When flying the sUAS within three (3) miles of an airport, airport operators will be notified and the 

operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. 

- Maximum flight time for each operation will be 30 minutes. 

- Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to

safely land the sUAS. 

- The sUAS will be pre-programmed so it will not be operated at an altitude that will exceed 200 feet 

AGL, and not more than 100 feet above an elevated platform from which videography is planned. 

- Minimum crew for each operation shall consist of: sUAS PIC and a visual Observer. 

- The sUAS operated by the Petitioner weighs less than 25 pounds, including all payload. 

- The sUAS will operate at speeds not to exceed 50 knots, can hover and can simultaneously move 

vertically and horizontally. 

- Given the small size of the sUAS and the restricted environment within which it will operate, TGC 

operations will adhere to the reform Act’s safety requirements. 
We respectfully request exemption under Section 333 to enable Gifted Studio, LLC to operate efficient,

limited, low-risk commercial sUAS operations for the activities stated respecting at all times the space 

and privacy of citizens and property while keeping airspace safe. 

Respectfully, 

Melissa S. Johnson 

Gifted Studio, LLC 

6421 Wolf Creek Tr. 

Cedar Rapids, IA 52411