UAS 333 Exemption Request

Sapient Film Productions

30797 Point Woods Ct

Temecula, Ca 92591

(520)730-6377

Total Pages: 
TO: FAA OFFICE OF REGULATIONS 

FROM: VINCENT JOSEPH, CEO, SAPIENT FILM PRODUCTIONS, LLC

SUBJECT: UAS Certificate of Waiver or Authorization (COA)

ENCLOSURE 1: DJI INSPIRE 1 MANUAL

ENCLOSURE 2: DJI S1000 MANUAL

ENCLOSURE 3: DJI S900 MANUAL

This letter serves as a request for exemption to operate Unmanned Aircraft Systems (UAS) in the 

collection of aerial footage for film and television production. This petition requests relief from 14 CFR 

part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates. The 

UAS(s) that will be used in media gathering will be purchased from a reputable vendor DJI with all 

systems having undergone extensive ground and in-flight testing prior to release.

Specific UAS models to be utilized in gathering aerial footage can be found in Enclosures 1-3 and will be 

registered with the FAA once the request for exemption has been approved by the FAA. Sapient Film 

Productions will create and implement extensive flight manuals designed to ensure UAS(s) are operated 

safely in order to prevent damage or injury to property and persons in the vicinity of UAS operations. 

These manuals will include required maintenance practices, pre-fight and post-flight procedures. All 

procedures will be approved by DJI who manufacturers UAS models utilized by Sapient Film Productions. 

Pilots involved in flight operations will be required to demonstrate proficiency with drone operations 

through preliminary and semi-annual check flights with the Vincent Joseph, CEO Sapient Film 

Productions who currently holds Fixed Wing and Rotary Wing Commercial and Instrument certifications.

The following procedures will be implemented to prevent damage, injury or death to persons and 

property in the vicinity of flight operations.

1. All Pilots will be required to show proof of Commercial Pilot Certification in Fixed Wing or Rotary 

Wing aircraft.

2. Pilots will undergo preliminary and semi-annual check flights with Vincent Joseph, CEO Sapient 

Film Productions to ensure pilot is capable to operate aircraft in accordance with FAA rules and 

regulations and in accordance with the manufacturers operating specifications.

3. Aircraft will undergo extensive pre-flight and post-flight inspections to ensure all components 

are undamaged and safe for flight according to manufacturer’s specifications.

4. Repairs will be completed and inspected by a manufacturer certified maintainer.

5. Aircraft will undergo complete maintenance inspection by a manufacturer certified inspector to 

ensure all loadbearing points, engines, internal circuitry, and safety systems are operating to 

manufacturer exact specifications.

6. Aircraft will contain redundant safety systems to ensure single component failure will not cause 

catastrophic failure.
7. Aircraft will contain system performance indicators to denote system health, airspeed and 

altitude and provide advanced warning of impending component or system failure allowing for 

the pilot in command to safely land the UAS.

8. Prior to flight, pilots will create and brief expected route of flight, route altitudes, all planned 

maneuvers and emergency landing zones along the intended route of flight.

9. Local FAA office will be notified of and briefed on all proposed UAS flights to include route of 

flight, altitudes, airspeed, intended maneuvers to be conducted and emergency landing zones 

located on the route of flight.

10. UAS will remain at or below 300 feet and fly at airspeeds of 15 knots or below. Should a need to 

exceed those parameters arise, approval from the FAA and/or control agency if near an active 

airport will be requested prior to modifying the previously briefed flight plan.

11. All aircraft will be available for FAA inspection at all times.

12. Aircraft will be marked with NIN and Sapient Film Productions, LLC contact information.

13. Pilots will hold current Class II medical clearance.

14. All pilots must have 50 hours of logged actual flight time in order to operate any UAS.

15. All aircraft will be non-aerobatic in nature. Aircraft will operate within manufacturer specified 

weight and center of gravity (CG) parameters. Aircraft loading will be 1 lb. or greater below 

manufacturer specified maximum loading weight to ensure propulsion systems are sufficient for 

safe flight.

16. Extensive pre-flight, mid-flight and post-flight checklists will be attained from DJI to ensure that 

the aircraft is operated according to exact manufacturer specifications at all times. 

17. Should the aircraft be operated in the vicinity of an active airport, a full flight plan shall be 

briefed and submitted to the FSDO and controlling agency and control frequencies shall be 

monitored via radio to ensure UAS does not pose a safety of flight hazard to other aircraft

operating in the vicinity of drone operations. Once UAS flight operations have been completed, 

the controlling agency in the vicinity of the UAS flight ops will be notified.

18. Pilot will operate within visual line of site (VLOS) of the aircraft at all times. This will be 

accomplished by mandating eyes on the UAS by the pilot or through individual spotters located 

at checkpoints along the UAS route of flight. Spotters will be in radio communication at all times 

to relay information quickly and accurately should a potential safety of flight issue arise. 

Spotters will be trained to provide course corrections in order to aid the pilot. The pilot will 

immediately initiate GPS hold and move to a location that is VLOS with the UAS if not confident 

with the spotter’s guidance.

19. Aircraft will operate in the 2.4 – 5.8 GHZ spectrum in accordance with the Federal 

Communication Commission (FCC) and will de-conflict radio frequencies as necessary to 

preclude an out of control flight situation.
20. FSDOs will be notified and briefed on intended flight plan to include altitude, route of flight, 

airspeed and planned flight maneuvers prior to commencing flight. Pilot will adjust flight plan as 

requested by the FSDO.

21. No Fly Zones will be honored at all times.

22. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office within 24 hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB).

23. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

24. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents will be made 

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

25. All aircraft will be identified by serial number, registered in accordance with 14 CFR part 47, and 

have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. 

Markings will be as large as practicable.

26. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough available power for the UA to conduct the intended operation and to operate after that 

for at least five minutes or with the reserve power recommended by the manufacturer if 

greater.

27. At least 3 days before aerial filming, the operator of the UAS affected by this exemption will 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The plan of activities must include at least the 

following: 

 Dates and times for all flights

 Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption

 Name and phone number of the person responsible for the on-scene operation of 

the UAS

 Make, model, and serial or N−Number of UAS to be used

 Name and certificate number of UAS PICs involved in the aerial filming

 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

 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 UAS, the UAS PIC, and the UAS operations will comply with and adhere to all applicable parts of 14 

CFR including, but not limited to, parts 45, 47, 61, and 91.

Respectfully,

____________________________

Vincent Joseph, CEO

Sapient Film Productions