Petition for Exemption 14 CFR § 11.81 Exemption petition under SEC 333.

Name: John Guarino, Shufflebox Productions, LLC 

Address: 15525 Kutztown Rd. Suite C Kutztown, PA 19530 

Phone: 484-648-2690 

Email: info@shuffleboxproductions.com

The specific section or sections of 14 CFR from which you seek an exemption;

I am requesting exemption from the following sections of 14 CFR that I believe meet the requirements 

for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95. 

I am requesting exemption from § 91.7(a) as it prohibits an operator from using an aircraft without an 

airworthiness certificate. This regulation is inapplicable becuase there is no certification applicable to 

the specific uses of my UAS.

I am requesting exemption from § 91.405(a), § 91.407(a)(1), § 91.409(a)(2) and § 91.417(a) and (b). All 

of these regulations detailing Maintenance Inspections apply only aircrafts with an airworthiness 

certificate. I will still be performing all maintenance and pre-flight regulations detailed in this agreement 

and the DJI Phantom manual.

I am requesting an exemption from § 91.119. The regulations in this section define the minimum safe 

altitudes for general aerial vehicles. My UAS will be flying no higher than 300 feet above ground level 

and will at no point be in congested or high traffic areas. Additionally, the maneuverability of the UAS 

will allow for a level of safety an equivalent to those in relation to minimum safe altitudes. 

I am requesting exemption from § 91.121 which details Altimeter settings. This regulation is inapplicable 

because the UAS makes use of electronic GPS for navigation and height settings. 

I am requesting exemption from § 91.151(a) which covers Fuel Requirements for flight. My UAS is 

powered electronically, and will issue notifications for low battery status. The battery also keeps flight 

time under 10 minutes at one time and will land automatically if the battery has exhausted all of its 

power.

How your request would benefit the public as a whole; 

My request benefits the public as a whole by providing an opportunity for corporations, business 

owners, agents of real estate and law, and any other individuals who wish to document their land or 

property using the very unique capabilities the UAS provides, and allows them to do so using an 

experienced RC operator that understands how to safely fly such technology. This would allow these 

organizations with a means of providing otherwise unavailable visuals for their business, its clients and 

other interests, thus increasing their marketing abilities and leading to growth of businesses and 

companies at an affordable cost. This will stimulate a safe and harmless economic growth in the 

community and its residents in which my business serves.
Reasons why the exemption would not adversely affect safety, or how the exemption would provide 

a level of safety at least equal to the existing rule;

Being an experienced RC UAS operator I would be a good candidate for exemption, and would not put 

Air Safety in any risk. The specific UAS (Phantom II Quadcopter) I am seeking exemption with is 

equipped with safety features, including GPS stability and navigation, as well as, real-time flight status 

and emergency LED beacons. When flying, I would generally be flying at a maximum altitude of 300ft in 

a very small and limited zone with slow movements, decreasing the risk of any interference. The UAS is 

battery powered and poses no risk to persons or the environment as it does not contain fuel or 

combustible liquids. My general knowledge of the FAA’s safety systems would be used to ensure that 

safety would not be affected by my operations. I would not be flying near any congested or disaster 

areas, sporting events, or high traffic areas including airports. The pre-flight checklist and maintenance 

procedures defined in the manual of this specific UAS (Phantom II Quadcopter) allow me to achieve a 

level of safety equivalent or higher to the existing rule.

Summary

I, John Guarino am seeking an exemption of Sec 333 of the FAA’s rules that does not allow the use of an 

Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safety. I am 

petitioning for an exemption to provide a commercial production service to private land owners and 

companies who wish to obtain and capture aerial photo and video of their property for purposes 

including real estate endeavors, event documentation, and for use as a marketing tool for business. I am 

an experience operator and technician with several hours of flight experience in varying conditions. I 

would be a good candidate for exemption of Sec 333 and would not put air safety at risk. The specific 

UAS (Phantom II Quadcopter) I am seeking exemption with is one with many safety programs, including 

GPS stability and navigation, as well as, real-time flight status and emergency LED beacons. When flying 

for this commercial purpose, I would generally be flying at a maximum altitude of 150ft in a very small 

and limited zone with slow movements, decreasing the risk of any unsafe flight. My general knowledge 

of the FAA’s safety systems would be used to ensure that safety would not be affected by my 

operations. I would not be flying near disaster areas, sporting events, or high traffic areas including 

airports. I appreciate the FAA’s consideration and time reading this petition for exemption. 

Additionally, I have a 2 million dollar liability insurance policy covering commercial use of the UAS listed in 

this petition. Thank you again for your consideration.