UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

___________________________________________________

STRATO AERIAL PRODUCTIONS,

 Petitioner.

Docket No. FAA-2015-_____

PETITION OF STRATO AERIAL PRODUCTIONS 

FOR AN EXEMPTION FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS 

Tim B. Adelman

Leclair Ryan, P.C.

180 Admiral Cochrane Drive, Suite 370

Annapolis, MD 21401

Phone: 410-224-3000

Fax: 410-224-0098

tim.adelman@leclairryan.com

Submitted on July 7, 2015
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TABLE OF CONTENTS

I. Petition for Exemption Summary

II. Interests of Petitioner

III. Proposed Conditions and Limitations for Petitioner’s Exemption

IV. Information Required to Support a Petition for Exemption

A. Contact Information of Counsel

B. Specific Sections of 14 CFR to be Exempt

C. The Extent of Relief Sought, and the Reason for Such Relief

D. Reasons Why an Exemption Would Further the Public Interest

E. Reasons Why an Exemption Would Not Adversely Affect Safety

F. Federal Register Summary

1. Exemptions Requested

2. Brief description of the nature of the exemption 

G. Additional Information Supporting an Exemption

V. Conclusion

Exhibit A – “Proposed Conditions and Limitations”

Exhibit B – “Manuals for DJI Inspire 1, DJI Phantom 2 and DJI S1000+”

Exhibit C – “Manual for Freefly Alta Aircraft”

Exhibit D – “Manual for Strato Aerial Productions Customized Aircraft”
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I. Petition for Exemption Summary

Strato Aerial Productions (“Strato”) seeks exemption from the requirements of 14 C.F.R. 

§§ 61.113(a) and (b) (private pilot limitations), 91.7(a) (airworthiness), 91.119 (minimum safe 

altitudes), 91.121 (altimeter settings), 91.151 (VFR fuel requirements), 91.405(a) (maintenance 

inspections), 91.407(a)(1) (return to service after maintenance), 91.409(a)(1) and (2) (annual 

inspection), and 91.417(a) and (b) (maintenance records). Strato seeks these exemptions to 

permit it to conduct Unmanned Aircraft System (“UAS”) operations on an independent 

contractor basis for film production companies over property owned, leased, or otherwise accesscontrolled by the film production companies with which Strato does business. Strato’s reasons 

for requesting an exemption are similar in all material respects to relief previously requested in 

Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 11423. 

II. Interests of Petitioner

Strato is an aerial cinematography company based out of Los Angeles, California. Strato 

seeks to participate in the film production business based in Los Angeles and surrounding region

of the southwest United States. With its fleet of five Unmanned Aircraft (“UA”), Strato will 

provide cinematography services to its clients as its clients shoot film for motion pictures, 

television programs, and commercials. 

The UAS operations covered by this exemption will all take place within accesscontrolled, secure environments managed by the production companies contracting with Strato 

for Strato’s UAS services. Strato’s UAS operations will be conditioned and limited as described 

in Section III of this Petition. The exemption will not adversely affect safety; rather, it will 

facilitate safe conditions on the production companies’ sets on which Strato will be providing its 
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UAS services. In furtherance of the goals of 14 C.F.R. § 11.81, the UAS operations utilizing still 

and video photography will be further the public interest.

III. Proposed Conditions and Limitations for Petitioner’s Exemption

Strato proposes that its UAS operations be conducted pursuant to the conditions and 

operating limitations set forth in Exhibit A – “Proposed Conditions and Limitations.” Each of 

the conditions and limitations set forth in Exhibit A is consistent with previously granted small 

UAS Section 333 exemptions and FAA guidance.1

IV. Information Required to Support a Petition for Exemption

A. Contact Information of Counsel

Strato Aerial Productions submits this Exemption Petition through counsel:

Timothy B. Adelman

LeclairRyan, P.C.

180 Admiral Cochrane Drive, Suite 370

Annapolis, MD 21401

Phone: 410-224-3000

Fax: 410-224-0098

tim.adelman@leclairryan.com

B. Specific Sections of 14 CFR to be Exempt

14 C.F.R. § 61.113 — Private Pilot Privileges and Limitations: Pilot in Command

Id. at § 91.7(a) — Civil Aircraft Airworthiness

Id. at § 91.119 — Minimum Safe Altitudes: General. 

Id. at § 91.121 — Altimeter Settings

Id. at § 91.151 — Fuel Requirements for Flight in VFR Conditions

Id. at § 91.405(a) — Maintenance Required

 

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See Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) (“Astraeus Exemption”); Exemption 

No. 11109 (December 10, 2014; Docket FAA-2014-0507) (“Clayco Exemption”); Exemption No. 11112A

(February 25, 2015; Docket FAA-2014-0382) (“VDOS Global Exemption”); Exemption No. 11213 (March 24, 

2015; Docket FAA-2014-0642) (“Aeryon Exemption”); and Exemption No. 11423 (April 24, 2015; Docket FAA2015-0152) (“Stunning Heights Exemption”).
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Id. at § 91.407(a)(1) — Operation After Maintenance, Preventive maintenance, 

Rebuilding, and Inspections

Id. at § 91.409(a)(1), (2) — Inspections

Id. at § 91.417(a), (b) — Maintenance Records

C. The Extent of Relief Sought, and the Reason for Such Relief

When Strato provides UAS operations services to its production company clients, Strato

will promote the safety, security, and well-being of all people and property involved by strictly 

abiding by the Proposed Conditions and Limitations set forth in Exhibit A. In order to conduct 

its proposed UAS operations with each of the five UA in its fleet, Strato requests exemptions 

from certain Federal Aviation Regulations that were intended to promote the safety of manned 

aircraft. 

To conduct its UAS operations, Strato petitions the FAA for an exemption from the 

following federal regulations for the reasons noted:

14 C.F.R. § 61.113 — Private Pilot Privileges and Limitations: Pilot in Command

Strato requests an exemption from § 61.113 to the extent necessary to permit Strato to 

conduct UAS operations with PICs holding FAA sport pilot certificates. In most instances, the 

FAA would require a pilot to hold a commercial pilot certificate where there is compensation 

either to the pilot or for the operation. Strato seeks waiver from this requirement, consistent with 

previously granted Section 333 exemptions (see footnote 1), because requiring the Strato pilots 

operating the UA in Strato’s fleet to adhere to the commercial pilot certification requirements 

will not improve the safety of operations. Requiring airman “aeronautical knowledge,” 

“aeronautical experience,” and “flight proficiency” at the commercial certificate level for those 

individuals operating a remote-controlled, battery-powered UAS aircraft operated in accordance 
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with the conditions and limitations set forth in Exhibit A would not bring the corresponding 

safety benefits contemplated in the manned commercial aircraft setting. Therefore, consistent 

with the certificate requirements imposed on the UAS pilots in recently granted Section 333 

exemptions, Strato requests the FAA grant an exemption from 14 C.F.R. § 61.113 and allow 

Strato’s UAS pilots who hold a FAA sport pilot certificate or recreational pilot certificate to 

serve as PICs for Strato’s UAS operations. 

14 C.F.R. § 91.7(a) — Civil Aircraft Airworthiness

Strato requests an exemption from the airworthiness certificate requirement because the 

aircraft flown in its UAS operations will not have an airworthiness certificate pursuant to 14 

C.F.R. Part 21, Subpart H. Strato understands that without an airworthiness certificate, it must 

inspect each aircraft before each flight to determine that it is compliant with Strato’s respective 

UAS Manuals which are provided in Exhibits B, C, and D. Strato bases this particular 

exemption request on the rationale that “[c]ompliance with [Strato’s] Manuals [is a] sufficient 

means for determining an airworthy condition.” Clayco Exemption, at 13.

14 C.F.R. § 91.119 — Minimum Safe Altitudes: General. 

Strato requests an exemption from this regulation so that its UAS operations may fly at 

low altitudes to better capture reliable video and still photography on behalf of its production 

company clients. Specifically with respect to subpart (c), Strato requests an exemption from the 

restriction that “aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure.” An exemption from subpart (c) will allow Strato UAS operations to better serve its 

clients by providing high-quality aerial video and still photography. 

14 C.F.R. § 91.121 — Altimeter Settings
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Strato requests an exemption from this regulation. While all UAS in Strato’s fleet use a 

barometric altimeter, it will be utilized and maintained in accordance with the manuals provided 

in Exhibits B, C, and D. Strato’s UAS pilots will check the aircraft’s altitude reading prior to 

each takeoff, and will effectively zero the aircraft’s altitude at the point of takeoff, to ensure that 

measurements of the aircraft’s altitude are accurate relative to the local elevation. Strato will 

also be conducting flights within visual line of sight (“VLOS”). If this approach is deemed to 

not satisfy 14 C.F.R. § 91.121, Strato requests an exemption so that Strato UAS operations can 

utilize this GPS signal methodology. 

14 C.F.R. § 91.151 — Fuel Requirements for Flight in VFR Conditions

Strato requests an exemption from this regulation to permit Strato UAS pilots to plan for 

less than 10 (ten) minutes of operating reserve time to be available at the end of each UAS 

operation. Strato’s UAS operations will all occur within the boundaries of property controlled 

by its production company clients. The takeoff and landing will occur within VLOS of the PIC, 

the PIC will maintain VLOS at all times during the flight, and the UA will be safely within the 

control range as established by its manufacturer. 

Strato understands that the policy behind this regulation is to account for unexpected 

weather conditions and logistical delays occurring during a flight or when an aircraft seeks to 

land at its first planned destination. Strato requests an exemption from this regulation because 

these considerations are not applicable here where Strato’s UAS operations will be hyperlocalized and will not realistically face the considerations undergirding the regulation’s policy. 

Moreover, a shorter reserve will be an additional safety mechanism by limiting the ability of the 

UA to fly far from its initial launch location. 

14 C.F.R. § 91.405(a) — Maintenance Required
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Strato requests an exemption from this regulation’s obligation to perform inspections and 

discrepancy repairs by FAA authorized mechanics. Strato proposes Conditions and Limitations 

in Exhibit A, that will require a level of maintenance consistent with the FAA’s standards 

communicated in the Astraeus Exemption and recently in the Stunning Heights Exemption. A 

copy of Strato’s Maintenance manuals are provided for FAA review in Exhibits B, C, and D. 

Strato’s exemption request regarding this regulation is limited to subpart (a) because it 

will make appropriate logbook entries in aircraft maintenance records in compliance with subpart 

(b), appropriately mark any inoperative instrument or item of equipment for which maintenance 

has been properly deferred in compliance with subpart (c), and appropriately placard listed 

discrepancies that include inoperative instruments or equipment in compliance with subpart (d). 

14 C.F.R. § 91.407(a)(1) — Operation After Maintenance, Preventive maintenance, Rebuilding, 

and Inspections 

Strato requests an exemption from this regulation to permit Strato to conduct its UAS 

operations without having to have the UAS approved for return to service by a person authorized 

under 14 C.F.R. § 43.7. Instead, Strato will maintain its UAs consistent with its own manuals

which will provide an adequate level of safety and will not adversely affect safety with regard to 

the regulatory maintenance and alteration requirements.

Strato has taken into account the conditions and limitations pertaining to UAS 

maintenance described in dozens of exemptions as Strato has written its own Proposed 

Conditions and Limitations. Strato proposes that its UAS maintenance be subject to scrutiny 

under its Conditions and Limitations in lieu of the requirement that it satisfy 14 C.F.R. § 

91.407(a)(1). Related to this regulation, Strato UAS operations will comply with subpart (a)(2) 

because Strato UAS operations will require completion of maintenance record entries. 

14 C.F.R. § 91.409(a)(1) and (2) — Inspections 
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Strato requests an exemption from this regulation so that Strato will not be required to 

obtain annual inspections and airworthiness certificate inspections required by this regulation. 

Instead, Strato will maintain the UAS in accordance with the maintenance manuals provided in 

Exhibits B, C, and D. Moreover, Strato will adhere to the Proposed Conditions and Limitations

in Exhibit A, which will provide a level of safety at least equivalent to that provided by this 

regulation and the requisite conditions and limitations described in the Astraeus Exemption, the 

Clayco Exemption, the VDOS Exemption, the Aeryon Exemption, and the Stunning Heights 

Exemption. 

14 C.F.R. § 91.417(a), (b) — Maintenance Records

Strato requests an exemption from this regulation so that Strato will not be required to 

keep the maintenance records described by this regulation. Instead, Strato will maintain the UAS 

in accordance with the manual in Exhibit B, C, and D. Moreover, Strato will adhere to the 

Proposed Conditions and Limitations in Exhibit A, which will provide a level of safety at least 

equivalent to that provided by this regulation and the requisite conditions and limitations 

described in the Astraeus Exemption, the Clayco Exemption, the VDOS Exemption, the Aeryon 

Exemption, and the Stunning Heights Exemption.

D. Reasons Why an Exemption Would Further the Public Interest

With the FAA grant of Strato’s exemption petition, Strato will be able to safely conduct 

its UAS operations under the Proposed Conditions and Limitations provided in Exhibit A. 

Granting this exemption would not set a precedent as the UAS operations proposed in this 

petition are substantially similar to the UAS operations discussed in the Astraeus Exemption, the 

Clayco Exemption, the VDOS Exemption, the Aeryon Exemption, and the Stunning Heights 

Exemption. 
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E. Reasons Why an Exemption Would Not Adversely Affect Safety

Strato’s UAS operations will be conducted over access-controlled property. This will 

allow Strato to be made aware of any pertinent circumstances that may affect its UAS operations. 

As such, Strato will be able to conduct its operations without adversely affecting safety. If the 

exception to 14 C.F.R. § 91.119 (the minimum safe altitudes provision) is granted, the UAS will 

be authorized to fly at low altitudes with little to no air traffic. Conducting its UAS operations at 

relatively low altitudes over access-controlled property will allow Strato to minimize safety risks 

created by its UAS operations. 

F. Federal Register Summary

1. Exemptions Requested

Strato Aerial Productions seeks exemption from the requirements of 14 C.F.R. §§ 

61.113(a) and (b), 91.7(a), 91.119, 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b).

2. Brief description of the nature of the exemption

The FAA exemption will permit Strato Aerial Productions to operate an Unmanned 

Aircraft System (“UAS”) over access-controlled property in the United States as a means of 

providing aerial cinematography services to production companies. Strato’s PICs will be trained 

pursuant to Strato’s Proposed Conditions and Limitations provided to the FAA with Strato’s 

Exemption Petition. 

G. Additional Information Supporting an Exemption 

Strato will readily provide additional information that the FAA might find helpful, or to 

answer questions in response to any FAA requests. A confidential copy of each of the manuals

will be submitted to the FAA Assistant Chief Counsel for International Law, Legislation, and 
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Regulations as supporting documentation for this petition. The manuals may contain proprietary 

information of Strato. Therefore, Strato requests that the FAA treat the manuals as confidential 

and not disclose them to the public. 

V. Conclusion

As set forth above, Strato seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012. The exemption will permit safe 

operation of the Strato UAS fleet for the special purpose of providing aerial cinematography 

services to production companies working in the United States. By granting this petition, the 

FAA Administrator satisfies the Congressional mandate of the FAA Modernization and Reform 

Act of 2012, while also advancing the public interest by allowing Strato to conduct UAS

operations over controlled-access property. 

Respectfully Submitted,

Tim B. Adelman

Leclair Ryan, P.C.

COUNSEL FOR STRATO AERIAL PRODUCTIONS