LOW SEA PRODUCTIONS, INC. 333 Exemption Request 

Sept. 24, 2015

Low Sea Productions, Inc. 

1126 Hollywood Blvd. 

Hollywood, FL

33019

Roger@LowSeaProductions.com

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

Dear Sir or Madam:

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

Low Sea Productions, Inc, (LSP) and owner Roger E. Lohse hereby apply for an exemption from 

Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small 

unmanned aerial systems for the primary purpose of aerial photography and video.

LSP will offer safe, low altitude, and cost effective aerial imaging to the communities we serve. 

A variety of industries will benefit; Home Real Estate, Commercial Real Estate, Marketing, Land 

Development, Construction, and Property Inspections.

LSP will operate a DJI Inspire 1, a small unmanned aerial system (sUAS) equipped with 

advanced flight control systems, high definition camera and gimbal, and advanced safety features. 

The sUAV will be operated by a responsible PIC (pilot in command) and VO (visual operator), in 

turn offering a safe and valuable experience to our clients.

1. The DJI Inspire 1 has a maximum takeoff weight of less than 6.5 pounds and thus offers a

light weight, small and compact video platform compared to manned aircraft.

2. The DJI Inspire 1 offers significant safety, noise, emission, security and environmental benefits

not available to larger manned aircraft.

3. The DJI Inspire 1 has numerous safety features such as failsafe mode, automatic landing 

should signal between PIC and UAS be interrupted, GPS based altitude and distance locks, flight 

limiting features and low battery warnings.

4. Dual controllers provide the PIC (pilot in command) to focus on operating the sUAS while a

second individual operates the camera.

5. Inspire 1 safety features are addressed in more detail in the attached Inspire 1 user manual.

The safe operation of the UAS will be the first priority before, during and after every operation.

1. All sUAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 200 

feet AGL.
LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request

Sept. 24, 2015

2. No sUAS operations will be conducted within 5 NM of an airport and will be in FAA class G

airspace.

3. No sUAS operations will occur directly over densely populated areas, un-approved government

buildings, power lines, or major roads.

4. All sUAS operations will take place during daylight hours under conditions equivalent to 

Visual Flight Rules (VFR) with the UAS no more than 1000 ft from the PIC.

5. All sUAS operations will have a PIC and VO present and all operations will be within visual 

line of sight (VLOS) of both the PIC and VO.

6. PIC and VO will be able to verbally communicate at all times.

7. The UAS will yield to all manned aircraft at all times.

8. All required permits and permissions will be obtained from local and state government should

they be required.

9. A pre-flight inspection by the PIC will be performed prior to each flight to assure that the UAS 

is safe for flight. A post-flight inspection will also be performed as an added level of safety.

10. Full aircraft inspections will be completed in accordance with manufactures instructions.

11. At no time shall the UAS be operated with missing or manufacturer unapproved parts, or in 

any condition that could pose a hazard to any other aircraft or structure or person on the ground.

12. The sUAS will not be operated at a battery level below 20%.

13. Prior to all UAS operations a pre-flight meeting will be held by the PIC to determine the

parameters of flight in a given location, any hazards present, weather conditions, safety

procedures at the specific location and approximate duration and route of flight.

14. The PIC will have a minimum of 10hrs flying time and operated atleast 50 individual flights 

of similar sUAS multirotor aircrafts. It is my belief that small unmanned aerial systems, used by 

experienced and responsible operators, following the policies outlined above, operating in privacy 

conscious way; will in turn offer aerial imaging to the general public in ways that are more cost 

effective, safe, and efficient than the traditional methods of manned aircraft.

I respectfully request the FAA to grant an exemption to Low Sea Productions, INC, for 

commercial UAS aerial photography operations under the Reform Act of 2012. If any of 

procedures, policies, or content of this request do not meet the requirements of an exemption, it	is	
Low	Sea	Productions,	Inc.’s		intention	to	adjust	its	policies	in	accordance	to	the	FAA’s	

requirements outlined in the granted exemption.

Sincerely,

Roger E. Lohse , President, Low Sea Productions, Inc.

1126 Hollywood Blvd. 

Hollywood, FL

754-581-2678

Roger@LowSeaProductions.com
LOW SEA PRODUCTIONS, INC. 333 Exemption Request 

Sept. 24, 2105

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Low Sea Productions Inc. (LSP) requests an exemption from the following regulations as well as 

any additional regulations	that	apply	to	the	operation	of	DJI	Inspire	1	or	similar	sUAS’s	for	

the	purpose	of	aerial photography and video.

14 C.F.R. 61.113(a) and (b) LSP will use specially trained staff to conduct the sUAS operations. 

While these individuals will not hold commercial pilot licenses, they will have at least 10hrs of 

flying time, have conducted at least 50 individual flights and read sUAS manufactures manuals 

and operating procedures. In addition each PIC and VO will be required to sign a document 

confirming the understanding of LSP operating and safety policies and the granted LSP 

exemption.

The sUAS will not carry property for compensation or hire since they will be used solely to

provide our clients with aerial imaging. Without an exemption, the pilot would be required to

hold a commercial pilot certificate under §61.133. However, the risk associated with the

contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at

altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other

aircraft, and within a geographical envelope under the sole control of LSP clients.

Requiring a commercial pilot certificate would provide no appreciable safety benefit and would

needlessly impose additional cost on LSP. Because the contemplated operations would not

comply with §61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is

needed from both paragraphs (a) and (b).

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate.

While the FAA continues to work to develop airworthiness standards for UAS, we request an

experimental certificate be issued for the UAS operated by the applicant under either or both of

the following provisions:

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

Research and development. Testing new aircraft design concepts, new aircraft equipment, new

aircraft installations, new aircraft operating techniques, or new uses for aircraft.

Showing compliance with regulations. Conducting flight tests and other operations to show

compliance with the airworthiness regulations including flights to show compliance for issuance

of type and supplemental type certificates, flights to substantiate major design changes, and
LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request 

Sept. 24, 2015

flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys,

sales demonstrations, and customer crew training, we would expect that an experimental

certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property and will only fly under strict operational

requirements.	As LSP’s sUAS	also	carries	no	combustible	fuel,	weighs	less	than	6.5	pounds

and is constructed primarily of plastics and composites, we propose the UAS is at least as safe, if

not significantly safer than conventionally certified aircraft used within similar parameters.

If an experimental airworthiness certificate is not appropriate for this application, then we

request an exemption of 14 CFR Part21, Subpart H, and the requirement for an airworthiness

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned

to the aircraft and a registration certificate must be aboard the aircraft.

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the

cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.”

As the sUAS is too small to carry documentation, does not have an entrance and does not carry

a crew, we propose the following in order to meet the intent of 91.203 and provide an

equivalent level of safety. All documents deemed appropriate by the FAA for this aircraft will be

located at the operational ground station for each flight in proximity to the PIC and VO and will

be available for inspection on request. In order to identify the aircraft, we propose to use the

manufacturer’s	model	and	production	codes	located	on	the	aircraft	as	well	as	a	RentaSky	

logo	affixed to the aircraft as well.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. The intent of this requirement is to ensure that flight manual

information is available to the aircrew while operating the aircraft.

LSP requests an exemption to this requirement as the UAS cannot, given its size, carry the

flight manual. To meet an equivalent level of safety, we propose to have the current

manufacturer’s	flight	manual	and	the	LSP	flight	manual	at	the	operational	ground station of 

each flight, available to both the PIC and VO.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated

closer than 500 feet to any person, vessel, system, or structure. Since the UAS will be operating

at a maximum 200 feet AGL, we cannot comply with this requirement and thus ask for an

exemption. In order to provide an equivalent level of safety, we propose the following.

The UAS will only be operated within VLOS of the PIC and VO at a maximum range of 1000 

feet from the ground station.
LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request 

Sept. 24, 2015

A preflight safety risk assessment will be completed prior to each flight to ensure the UAS is in a

condition for safe flight and that the planned operation can be completed	safely.		LSP’s

Flight Manual and Pre-Flight Checklist is included as Appendix A and Appendix B.

The UAS will not be operated within 5 NM of any airport and will only be operated with the

consent of property manager and/or owner.

14 CFR 91.121 Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft.

The UAV will always be flying below 200 feet AGL within VLOS of the PIC and VO that will

provide separation from terrain, structures and other aircraft. Also, the UAS will continually

transmit an AGL reading back to the controller at the ground station and the AGL lock in the

UAS’s	software	will	be	set	to	400	feet,	providing	an	equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. The UAS is smart battery powered and continually transmits battery 

charge information back to the ground station to be evaluated by the PIC who will return the UAS 

back to the ground station prior to the battery showing 20% remaining capacity. We feel that this 

combined with the fact that the UAS will have a maximum range of 1000 feet from the ground 

station provides an equivalent level of safety.

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

Maintenance, Preventive Maintenance, and Alterations.

We propose	that	the	PIC	perform	maintenance	and	inspection	and	“be	authorized	to	

approve the	aircraft	for	return	to	service.”	As	provided	for	in	Appendix	A,	the	PIC will 

inspect the aircraft prior to every flight to ensure it is in airworthy condition. A maintenance 

check will also be performed at intervals instructed by the manufacturer, DJI. Any general 

maintenance and repair or replacement of components will be completed	by	the	PIC	following	

the	manufacturer’s recommendations and documented in accordance with 91.417. In any case 

where the UAS cannot be returned to service by the PIC, or is suspected to be unsafe, the UAS 

will not be operated until returned to all manufacturer specifications. We feel that due to the 

simplicity, size, robustness and construction of the aircraft, the PIC can assure an equivalent level 

of safety.

8900.227 Paragraph 16(cXa) PIG Medical. and Paragraph 16(eX1) Observer Medical

This policy provides that both the PIC and observer must have a valid FAA second-class medical

certificate issued under part 67 in order to perform as a pilot or observer. We feel that

requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying

passengers in a large aircraft is an unnecessary burden. Since the UAV is of small size, 
LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request 

Sept. 24, 2015

unmanned, has an auto return home feature, will be operating at low altitudes, will not operate 

over a densely populated area, and required to be in VLOS of the IC and VO at all times, we feel 

both the PIC and VO requiring vision corrected to 20/20 and a valid	state	issued	driver’s	license	

supports	medical	requirements.

APPENDIX A

Low Sea Productions, Inc. Flight Parameters and Restrictions:

1. All flights will occur in FAA Class G airspace at no more than 200 feet AGL and no further 

than 1000ft from the PIC.

2. The sUAS will not be flown faster than 40mph or as limited by FAA regulations.

3. All operations will utilize a PIC and VO with the PIC and VO able to communicate verbally at 

all times.

4. All operations will occur only during daylight hours and in weather conditions equivalent to 

VFR.

5. All operations will occur at VLOS from the PIC and VO.

6. The PIC and VO will have a pre-flight meeting at the site of the operation just prior to the 

flight to assess weather, area of operation, topography, flight time, route, hazard mitigation and

overall operational and safety parameters. Also during this meeting, the pre-flight aircraft

checklist (see Appendix B) will be implemented.

7. PIC is responsible for maintaining an established safe emergency landing plan if at any time

during the operation conditions become unfavorable due to unforeseen hazards, safety

concerns, or weather.

8. All operations will be reviewed prior to flight and conducted with the full permission of the

property owner or manger.

9. Flight planning will include the termination of the flight with 20% battery remaining, as

determined by the data link between the UAS and ground station.

10. The UAV will at all times give way to manned aircraft.

11. Prior to every flight, a highly visible launch banner will be placed at the site of the ground 

station to	allow	an	outside	observer	to	determine	the	location	of	the	UAS’s	origin	and	

command	point.

12. All permits required by state and local governments will be obtained prior to any operations.

13. No flight operations will occur without a successful pre-flight inspection by the PIC before
LOW SEA PRODUCTIONS, INC. FAA 333 Exemption Request 

Sept. 24, 2015

each flight to determine that the UAS is in a condition for safe flight.

14. At the conclusion of each flight a post-flight inspection will be done to assess the condition of

the UAS.

15. A full aircraft check will be performed in accordance with manufactures instructions.

16. Replacement	of	parts	shall	only	be	done	according	to	manufacturer’s	instructions.

17. All flight operations will be logged in a flight logbook.

18. All maintenance done and inspections performed will be lodged in a maintenance log.

19. Check for software updates weekly and upload to UAS as needed to continually keep the 

UAS software as current as possible.

APPENDIX B

Low Sea Productions, Inc. Pre-Flight Checklist:

1. Ensure the area identified for flight is considered FAA Class G airspace, winds conditions are 

less than 15mph, and weather conditions are favorable.

2. Identify all potential obstructions and safety hazards in or near the area planned for flight.

3. Inspect all propellers for proper tightness and that they are free of cracks, dings, chips and

excessive wear.

4. Inspect all wiring and motors.

5. Inspect the airframe for cracks or damage.

6. Inspect battery voltage of UAS on-board battery and Remote Controller/Transmitter battery to

ensure there is sufficient energy in both systems for safe flight.

7. Turn off WiFi wireless on all devices located the person or within 10ft of the PIC and VO.

8. Recalibrate compass according to manufacturer’s	instructions.

9. Always turn on Remote Controller/Transmitter before turning on UAS battery.

10. Ensure that a link between Transmitter and UAS is established and that GPS link is 

established.

11. Engage throttle, lift aircraft off the ground and verify the aircraft responds properly to all 

inputs and hovers accurately.