June 28, 2015

Anton Ewing

Video Solutions, LLC

2175 Cowley Way

San Diego, CA 92110

619-719-9640

Anton@antonewing.com

Petition for Exemption

Federal Aviation Administration

Re: Unmanned Aircraft System (DJI Phantom Quadcopter drone) use in NAS for compensation

Petitioner, Anton Ewing, hereby petitions the Federal Aviation Administration (FAA) on 

behalf of himself and his employer, Video Solutions, LLC, for an exemption from Part 21; §§ 

45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 

91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow operation of 

unmanned aircraft systems (UAS) for the purpose of scripted, closed-set filming for the motion 

picture and television industry.

The terms and conditions of Grant of Exemption No. 11062 are hereby incorporated by 

this reference as if fully set for herein with the exception of the mandatory 3rd class medical 

certificate.

Petitioner hereby proposes the following terms and conditions for the grant of the 

exemption requested herein:

The UAS proposed by the petitioner is a proprietary design, conceived and constructed 

by Video Solutions, LLC. The UAS is referred to as a DJI Phantom Quadcopter, and has four 

rotors and four motors in a quadcopter configuration. The UAS referenced herein is under 45 

lbs, will be flown at all times under 300 feet AGL as measured by the UAS GPS system, kept 

within line of sight of the Pilot in Command, will have a separate safety observer at all times in 

communication with the PIC within 5 feet of eachother, will not be flown in excess of 40 miles 

per hour, never flown at night, always using Visual Flight Rules and within visual line of sight, 

never using first person view by the PIC, the PIC will be able to use human vision unaided by

any device other than corrective lenses as specified by a current state issued drivers license, with 

72 hours advance notice to the local FSDO of flight operations, the PIC will have over 400 hours 

of logged flight experience in the same UAS type or model, including 10 take offs and landings 

within the prior 30 days, and a full and complete inspection of aircraft by the PIC prior to take 

off.
The PIC will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements must 

be established and identified in the operator’s manual. At a minimum, the following will be 

included in the operator’s manual: 

a. Actuators / Servos 

b. Transmission (single rotor) 

c. Powerplant (motors) 

d. Propellers 

e. Electronic speed controller 

f. Batteries 

g. Mechanical dynamic components (single rotor) 

h. Remote command and control 

i. Ground control station (if used) 

j. Any other components as determined by the operator 

Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

is prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight in accordance with the operator’s manual. The PIC who conducts the functional test 

flight must make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to the operator’s 

manual. 

Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight time and 

90 day currency. During training, proficiency, experience-building, and take-off and landing 

currency flights all persons not essential for flight operations are considered non-participants, 

and the PIC must operate the UA with appropriate distance from non-participants in accordance 

with 14 CFR § 91.119. 
Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in the

operator’s manual. As this is a requirement stipulated by the operator, the test must be developed 

and implemented by a qualified person designated at the sole discretion of the operator. A record 

of completion of this qualification process must be documented and made available to the 

Administrator upon request. 

Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical test 

standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual. 

The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface in 

the event of a UAS failure or emergency. 

Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons must 

be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary

for reductions to the distances specified in the petitioner’s manuals. This is consistent with the 

manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of 

Waiver for Motion Picture and Television Filming.

Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet if it 

would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the 

filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such 

barriers may protect non-participating persons (observers, the public, news media, etc.) from 

debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, 

C8, S1. 

If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the operator’s manual. 
The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

Each UAS operation must be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 

The PIC will request a NOTAM not more than 72 hours in advance, but not less than 48 

hours prior to the operation.

The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures must be added to the operator’s 

manual. 

Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual. 

Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the UAS filming production conducted under 

this grant of exemption 

c. Name and phone number of the person responsible for the on-scene operation of the UAS 

d. Make, model, and serial or N-number of UAS to be used 

e. Name and certificate number of UAS PICs involved in the filming production event 
f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must be 

made available to the inspector upon request. 

g. Signature of exemption-holder or representative 

A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation 

The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at 

the ground control station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request. 

The UA must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

The UAS cannot be operated by the PIC from any moving device or vehicle. 

The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 

The UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided. 

Unless otherwise specified in this grant of exemption, the UAS, PIC, and operator must 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
The Federal Aviation Administration by and through its authorized representative is 

requested to approve this petition based on the above terms and conditions for a certificate of 

authority and certificate of exemption to operate within the above parameters for compensation 

or hire within the United States National Air Space.

Respectfully submitted:

/s

Anton A. Ewing

Your Comment Tracking Number: 1jy-8f1u-eh3l