VS3 STUDIOS, LLC.

P.O. BOX 2893, WESTERVILLE, OH 43086

(740) 513-4899 | VS3STUDIOS@GMAIL.COM

PETITION FOR EXEMPTION

December 17, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW 

Washington, 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 Federal 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 stayed 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 THE AIRCRAFT FOR PROPOSED OPERATIONS

DJI Phantom 3 Standard

THE PROPOSED OPERATIONS

Provide aerial photography and videography to clients 

HOW THE OPERATOR WILL MAINTAIN AN EQUIVALENT 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 altitude
2. Gyro stabilized flight

3. Ground 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 enhances performance for entry AP 

with position hold, return-to-home and intelligent orientation control. With GPS Module, the 

multi-rotors will have position and altitude lock 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 disconnected, the outputs of all command sticks from controller 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. Propeller guards

VS3 Studios, LLC, will not fly in adverse weather conditions such as high winds or reduced visibility

and ensure 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 operating area associated with the aircrafts to be utilized by VS3 Studios, 

LLC, an exemption from Part 21 meets the requirements 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, fuselage, 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 commercially certified 

pilot would not correlate to the airmanship skills necessary for similarly proposed operations in 

previously issued exemptions to this regulation through exemption

Nos. 11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness

There is no certificate applicable to the UAs in question, this regulation is inapplicable. However, VS3 

Studios, LLC, will register 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 electricity, 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 airworthiness 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

Alteration

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 be granted since they only apply to aircraft with 

an airworthiness certificate. However, VS3 Studios, LLC, will perform preflight inspections of the 

UAS before each flight as outlined in the operating documents. 

HOW GRANTING THE EXEMPTION WOULD BE IN THE PUBLIC INTEREST

Aerial photography and videography as an available 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 significantly more noise, and are more threatening 

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

In addition, as mentioned in the Trudeau exemption, No.11138: “Manned aircraft conducting aerial 

filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry 

other onboard crew members, as well as 100 gallons or more 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 reduces 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.