2015-12-14

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE 

Room W12-140 West Building Ground Floor

Washington DC 20590-0001 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations 

Dear Sir or Madam, 

I respectfully request exemption under Section 333 of the FAA Reform ACT and 

Part 11 of the Federal Aviation Regulation in order for my company FOCAL 

POINT PRODUCTIONS, INC (FPP) to utilize small Unmanned Aircraft Systems 

(sUAS). 

FPP is a small video production company based in Baltimore County, Maryland. 

The company was started in 2000, and produces training/instructional, 

promotional, special event, marketing, and real estate videos for small business, 

corporations, government entities, non profits, and private individuals. We intend 

to incorporate the use of a sUAS for a variety of projects for the purpose of ariel 

photography and ariel videography for the types of productions listed above. 

Petitioner: 

Martin Samuel Jenoff

Focal Point Productions, Inc. 

Telephone: 410-701-0377 

 Email: Marty@focalpp.com 

Extent of relief requested: 

To permit commercial operation of a sUAS for operations conducted within and 

under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

Said exemption would permit the operation of sUAS under controlled conditions 

in limited, predetermined and controlled airspace. Upon granting of this proposed 

exemption request, FPP would conduct commercial operations of sUAS meeting 

physical address: 

8 Music Fair Road, Suite D 

Owings Mills, MD 21117

mailing address: 

PO Box 401 

Owings Mills, MD 21117

Focal	Point	Produc.ons

PO	Box	401,	Owings	Mills,	MD	21117

Phone:	410-701-0FPP	(0377)	|	Web:	www.focalpp.com
or exceeding all operational and safety requirements per Section 333. 

Specific Sections(s) seeking exemption: 

 • 14 C.F.R Part 21 

 • 14 C.F.R. 45.23(b) 

 • 14 C.F.R. 61.113(a) 

 • 14 C.F.R. 91.7(a) 

 • 14 C.F.R. 91.9(b)(2 

 • 14 C.F.R. 91.109 

 • 14 C.F.R. 91.119 

 • 14 C.F.R. 91.121 

 • 14 C.F.R. 91.151(a) 

 • 14 C.F.R. 91.203(a) and (b) 

 • 14 C.F.R. 91.215 

 • 14 C.F.R. 91.104 through 91.417 

Equipment: 

Upon received a waiver, FPP will acquire a DJI Phantom 3 quad copter. The 

Phantom 3 is equipped with built-in GPS-enabled “geofence” preventing the pilot 

from accidentally flying into unwanted areas or obstacles. The unit also features 

vision positioning with sensors that scan the ground enabling it to identify 

patterns to position and move more accurately. Additional safety features include 

an auto-takeoff feature as well as a GPS-powered “Auto Return Home” feature 

where at the touch of a button, the unit will fly back to its take-off location 

automatically in the event of low battery or a lost connection. For additional 

safety and control, the Phantom 3 is equipped with a live-video feed sent to a 

tablet, phone, or video monitor connected to the remote control for real-time 

operator awareness and vision. Also displayed are all flight details including 

location, speed, height, distance, battery power and general aircraft conditions. 

Flight time is approximately 23 minutes. All flights will begin with a pre-flight 

checklist. Flight logs are captured automatically and include route, flight time, 

distance and location. 

Quad Copter Specifications: 

 • Weight (Including Battery And Propellers): 2.822 lb 

 • Diagonal Size (Including Propellers) 23.23 in 

 • Max Ascent Speed: 5 m/s 

 • Max Descent Speed: 3 m/s 

 • Hover Accuracy 

 • Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

• Horizontal: +/- 1.5 m 

 • Max Speed: 16 m/s (ATTI mode, no wind) 

 • Max Altitude Above Sea Level: 6000 m 

 • Operating Temperature: 0°C to 40°C 

 • Gps Mode: GPS/GLONASS 

Remote Control Specifications: 

Focal	Point	Produc.ons

PO	Box	401,	Owings	Mills,	MD	21117

Phone:	410-701-0FPP	(0377)	|	Web:	www.focalpp.com
• Operating Frequency: 2.400 GHz-2.483 GHz

• Max Distance: 2000m (outdoors and unobstructed) 

 • Video Output Port: USB

• Operating Temperature: 0°C- 40°C

• Battery: 6000 mAh LiPo 2S

• Mobile Device Holder

• Receiver Sensitivity (1%Per): -101 dBm ±2 dBm 

• Transmitter Power (Eirp) • FCC: 20 dBm 

• CE: 16 dBm

• Working Voltage: 1.2 A @7.4 V 

Public Benefit: 

Aerial photography and videography can cost thousands of dollars when the use 

of manned fixed-wing aircraft or helicopters is required. That is a cost-prohibitive 

hurdle for many small businesses and non profits. By utilizing a sUAS, we will 

provide this service at a significantly lower cost, making aerial photography and 

videography available to more businesses. Further, the sUAS can be operated 

much more safely and at less risk to the public than helicopters and fixed winged 

aircraft. 

Safety: 

Provided an exemption is granted, we will comply with all the following conditions 

and limitations: 

 • Operations will be limited to the DJI Phantom 3; 

 • Flights will be operated within the visual line of sight of the pilot; 

 • Flights will be operated only during daylight hours; 

 • Maximum total flight time for each operational flight will be thirty (30) 

minutes. Flight times may be less than thirty (30) minutes as the UAS will 

continuously monitor battery reserve and return to the ground station with 

at least 20% battery power reserved; 

 • Flights will be operated at an altitude of 200 feet AGL. Flights will never 

exceed 400 feet AGL; 

 • Minimum crew for each operation will consist of the sUAS pilot and a 

Visual Observer; 

 • A briefing will be conducted daily by all personnel working with said sUAS; 

 • All onsite personnel and client employees will be required to execute a 

waiver. Verbal/written consent will be required of all persons within 100 

feet of flight operation; 

 • Written and/or oral permission from relative property owners will be 

obtained prior to operating the sUAS; 

 • All permits, permissions, etc. will be obtained from local government 

offices as required; 

 • The sUAS operated will weigh less than 55 pounds including payload 

(camera, lens, gimbal, etc.); 

Focal	Point	Produc.ons

PO	Box	401,	Owings	Mills,	MD	21117

Phone:	410-701-0FPP	(0377)	|	Web:	www.focalpp.com
 • The sUAS will operate at speeds less than 30 knots, hover and 

simultaneously move vertically and horizontally; 

 • The sUAS will have the capability to return and land at the pre-determined 

location with the Security Perimeter should the sUAS lose communication 

or GPS signal during any operations; 

 • The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies; 

 • Operations will not be conducted over densely populated areas or heavily 

traffic highways. 

 • Contact respective airports if operations will be within 5 miles to advise 

them of estimated flight time, flight duration, elevation of flight and other 

pertinent information. 

On behalf of Focal Point Productions, I want to thank you for your consideration 

in granting this exemption. It would be our honor to hold this designation and 

would represent a growth opportunity for my business and our clients. 

Sincerely, 

Martin S. Jenoff 

President 

Focal Point Productions, Inc.

Focal	Point	Produc.ons

PO	Box	401,	Owings	Mills,	MD	21117

Phone:	410-701-0FPP	(0377)	|	Web:	www.focalpp.com