Date: March 2, 2015

U. S . Department of Transportation Docket Management System 

1200 New Jersey Ave., S E 

Washington, DC 20590 

Petition of Steven Strickler and MindMotion Films for Exemption 

Pursuant to Section 333. of the FAA Reform Act. 

Filed by: 

Steven Strickler, Owner 

MindMotion Films

824 First Street 

Lancaster, PA 17603 

888-519-9995 

1. The Petitioners, Mind Motion Films and Steven Strickler, (MMF) have 

been engaged in the film, photography, and videography for over twenty years. 

MMF provides full service photography, videography, and film-making to clients 

on site and at its video production facility.

2. Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the Reform Act) and 14 C.F.R. Part 11, MindMotion Films (MMF), an 

operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial 

photography and videography, hereby applies for an exemption from the listed 

Federal Aviation Regulations ("FARs") to allow commercial operation of its 

sUASs, so long as such operations are conducted within and under the conditions 
outlined herein or as may be established by the FAA as required by Section 333.1 

3. The Petitioner requests exemption from the following Regulations: 4 

C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 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) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14C.F.R. (91.401-91.417) 

4. MindMotion Films uses and would like to bring the capabilities of an 

sUAS to its on site videography and photography business. MMF utilizes and 

proposes to utilize SUASs to film on site at private land. 

5. The requested exemption would permit the operation of small, unmanned 

and relatively inexpensive UAS under controlled conditions in airspace that is 1. 

Limited 2. Predetermined and 3. Controlled. The proposed exemption, if granted, 

would allow MMF to conduct commercial operations of small, unmanned aircraft 

systems ("UAS") meeting or exceeding all of the operational and safety 
requirements Congress has set forth in Section 333. 

6. MMF utilizes and would utilize sUASs for multiple clients in a number of 

ways for the creation for videography and film making for TV/Broadcast, local 

governments and business, for profit corporations, non-profit corporations, 

educational and research videography and film making. 

7. Statutory Authority Section 333, titled "Special Rules for Certain 

Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA 

authorization of safe civil UAS operations in the NAS. Section 333(a) states that 

the FAA "shall determine if certain unmanned aircraft systems may operate safely 

in the national airspace system before completion of the (comprehensive) plan 

and rule making required by section 332(b)(1) of this Act or the guidance required 

by section 334 of this Act." In Section 332(b)(1), Congress made it clear that 

Section 333 provides a mechanism for "expedited operation authorization" if 

several factors are met. Petitioner meets all requirements to permit FAA approval 

of commercial UAS operations. 

8. Unmanned Aircraft System sUAVs are superior to helicopters due to their 

small size, lower cost, reduced noise and limited environmental impact, which 

promotes public safety. ·

9. MMF petitions to operate two sUAVs: a 1) DJI Inspire-1 model and 2) 
DJI Inspire-1 Pro with a weight of about 8 or 9 lbs. Both the DJI Inspire-1 and 

DJI Pro-1 utilizes HD cameras and is equipped with a three-axis gimbals and 

using High-Def cameras. 

a. Both the Inspire 1 and Inspire 1 Pro has several built in capabilities to 

limit the height it flies above the ground, to limit the radius of the distance it flies 

from the operator and to exclude it from Class 8, C and D airspace including a nofly zone feature a Return to Home mode, Failsafe, and Return to Home modes. 

b. Both the DJI Inspire-1 and Inspire 1 Pro meet with the Model Aircraft 

Operating Standards. 

c. MMF will only operate its sUAS in line of sight of a pilot and/or observer 

and will operate at sites that are a 'sufficient distance' from populated areas within 

the sterile area described in the FOPM. Such operations will insure that the sUAS 

will "not create a hazard to users of the national airspace system or the public." 

 · When flying sUAV within 5 miles of an airport, airport operators will be 

notified and the operator will give the right of way to avoid flying in the 

proximity of full-scale aircraft. 

 · Maximum flight time for each operational flight will be 20 minutes. Flights 

will be terminated at 20% battery power reserve should that occur prior to 

the 20 minute limit. 
 · The sUAV will be programmed so that it will not be operated at an altitude of 

no more than 400 feet AGL, and not more than 200 feet above an elevated 

platform from which filming is planned. 

 · Minimum crew for each operation will consist of the sUAS Pilot, and Visual 

Observer. 

 · The sUAS operated by the petitioner weighs less than 55 pounds, including 

the payload (i.e. camera, lens, and gimbal) . 

 · The sUAV will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally . 

 · Given the small size of the sUAS and the restricted sterile environment 

within which they will operate, our sUAS operations adhere to the Reform Act's 

safety requirements. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel, it operates at lower altitudes with no 

people on board and will thereby reduce current risk levels and thereby enhance 

safety and diminish the likelihood of death or serious bodily injury. With a small 

payload and maximum flight time of only 20 minutes, this is offers little or no risk 

to national security, personal property, or larger aircraft. Low level oblique photos 
and video from several angles are far more effective than ground based imagery 

for displaying the characteristics of large, complex properties with several 

buildings· and large trees. The benefits of reduced cost and improved quality of 

presentation from the UA will be valuable to and benefit many buyers and sellers 

of real property. Additionally, we request that we be allowed to use our system to 

film for marketing and promotional materials for clients on their own private 

property within a 200 feet AGL. 

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b)AII operations must occur in FAA Class G airspace at no more than 400 ft 

AGL, at an airspeed of no more than 25 knots and no further than 1/8th NM from 

the PIC; (c)AII operations must utilize a visual observer (VO). The VO and PIC 

must be able to communicate by voice at all times during a flight operation;

(d)Operations will be restricted to flights over private property with the 

permission of the property owner; 

d. All required permits will be obtained from state and local government 

prior to operation; 

e. MMF will not be operate over densely populated areas; (g) MMF 

Photography, will not be operating over any open-air assembly of people; 

f. MMF will not be operating over heavily tracked roads; (i) MMF will not 

be operating within 5 NM of an airport or heliport without prior permission. 

WHEREFORE, MMF respectfully request exemption under Section 333 to enable 
MMF and Steven Strickler, to operate efficient, limited, low-risk commercial sUAV 

operations for the activities stated respecting at all times the space and privacy of citizens 

and property whilst keeping our skies safe. 

Respectfully Submitted, 

Steven Strickler, Owner 

Mind Motion Films 

ADDENDUM TO PETITION 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Steven Strickler and Mind Motion Films request an exemption from the following 

regulations as well as any additional regulations that may technically apply to the 

operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the DJI Inspire 1 under 

either or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes: (a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations 

to show compliance with the airworthiness regulations including flights to show 

compliance for issuance of type and supplemental type certificates, flights to substantiate 

major design changes, and flights to show compliance with the function and reliability 
requirements of the regulations. Since the experimental certificate can be used for 

commercial purposes such as market surveys, sales demonstrations, and customer crew 

training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and 

will only fly under strict operational requirements. 

Combined with the UA's lightweight, being constructed primarily of carbon fiber and 

plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental airworthiness 

certificate is not appropriate for this application, then we request an exemption of 14 CFR 

Part 21, Subpart H. and the requirement for airworthiness certificate in general. Citing the 

equivalent level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of

the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph will 

provide the aircraft's registration information at the ground station. Finally, we will 

display at the ground station a high contrast flag or banner that contains the words 

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft 

will operate within 3/4 NM of the ground station, the banner should be visible to anyone 

that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as 

pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 
private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire. Our proposed 

operations require that the PIC 

must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft 

cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph 

(b) even though the intent of this application is to conduct a business. 14 CFR 91.7 

Prohibits the Operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved sUAS 

Flight Manual must be available to the crew at the ground station anytime the aircraft is 

in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests 

The regulation states that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." The sUAS 

System ground based control station consists of a small hand-held radio transmitter and 

while it does not offer a second set of "controls", both the student 

and instructor can, and will, operate the single set of controls simultaneously. With both 

student and instructor having "hands-on" the controls during flight, we feel that this 

technique meets the intent 91.109 and provides an equivalent level of safety. ·
91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the sUAS would be photography or 

survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons 

where permission has been obtained and careful pre-planned has been performed. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be considered in 

granting the exemption. ·

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising

altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The 

sUAS will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter 

measurement above the takeoff point is transmitted via radio from the sUAS on-board 

computer to the d1splay screen held by the PIC, providing a constantly updated AGL 

readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day- VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated 

and the maximum duration of flight from a single battery charge is 18 minutes with a 

20% reserve. Since the aircraft will never fly more than 1/8 NM from the point of 

intended landing, a full battery charge 

at launch will ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent interpretation with the 

word

"energy". 
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the 

aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be 

"displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 

pounds, the sUAS is too small to carry documentation, does not have an entrance, and is 

not capable of carrying passengers or crew. To obtain an equivalent level of safety and·

meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft 

by the FAA will be located with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that the information 

found on airworthiness and registration certificates be permanently affixed to the aircraft 

via placard containing the following information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 

14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations. 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43. 7" after maintenance and inspection. It is our intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every 

two hours of flight. Maintenance performed by the PIC is limited to repairing small 

cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. The manufacturer or their designated repair facility 

will perform all other maintenance. The PIC will document work performed in 

accordance with 91.417. We feel that due to the size, construction, and simplicity of the 

aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAS. MMF will be using the UAS in a variety of 
applications that generally require expensive full-size manned aircraft to complete. Small, 

light, unmanned aerial vehicles offer myriad benefits over the use of full-sized manned 

aircraft for electric power line inspection, oil/gas pipeline inspection, advanced 

agriculture, film and still photography, just to name a few. Replacing significantly larger 

manned aircraft carrying crew and flammable fuel with small UAS carrying no 

passengers or crew creates a much greater margin of safety for the pilots and crew. By 

granting MMF requested exemptions, the FAA will help drive development of safe and 

successful commercial UAS operations and will advance the public knowledge base for 

such operations. Middle Tennessee Aerial Photography is committed to promoting

the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA 

by sharing data from its commercial UAS operations and serving as a resource for future 

UAS research operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the SUAs which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the 

line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with 

aviation activities, unless the air traffic control authorities (ATC) have been notified and 

have authorized each flight within a radius of this distance. 

The Inspire 1 and Inspire 1 Pro have proven capability for controlled flight. They are 

devices offered for general sale on the market around the world and have often been used 

as Model Aircraft in the USA. Studies studies conducted until now by the FAA, about 

Section 332, Public Law 112 -95, 2014, have already provided you with the assurances 

on the airworthiness of SUAs such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and 

should be permitted to conduct small UAS operations in accordance with its manuals and 

all other operating parameters deemed necessary and appropriate by the FAA. The 

submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some SUAs may be used for 

legitimate commercial activities and under reasonably safe conditions.