December 1, 2015

Docket Operations, M-30

US Department of Transportation

Federal Aviation Administration

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 of 2012 and 14 CFR Part 11, 

including also: 14 CFR Part 21, 45.23(b), 61.113 (a) & (b); 91.7 (a), 91.103; 91.119(c); 1.121, 91.151 (b); 

91.405 (a); 91.405(a); 91.407 (a) (1); 91.409 (a)(1) and (2); 91.417 (a) and (b) for the operation of an 

unmanned aircraft system pursuant thereto.

Submitted on behalf of:

Chair 8 Media, LLC

Mr. Cameron Barker

Managing Member

720 Kimbrough Street

Raleigh, North Carolina 27608-2724

cam@chair8media.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR part 11, Chair 8 

Media, LLC hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below

to allow commercial operation of its unmanned aircraft systems (UASs) in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

Relief is being sought because the use of UASs in the course of conducting a commercial enterprise or 

activity is prohibited without a Section 333 exemption. The requested exemption would permit Chair 8 

Media to pursue its commercial interest in providing professional aerial photography services to clients 

using a small unmanned aircraft (UA) to photograph developed and developable commercial, industrial, 

recreational and residential real estate, including both video and still photography, and to engage in other 

aerial photography activities for its clientele.

Benefits to the public from the operation of a UAS by Chair 8 Media would include (1) a reduction in

emission of greenhouse gases, (2) less danger to the public and to property if the UA were to crash due to

the smaller weight and overall size of the UA when compared to larger manned aircraft, and (3) less 

expense of operation which would help make the benefits of aerial photography accessible to more 

businesses and the public than traditional aerial photography from manned aircraft. 

Commercial operation of the Chair 8 Media’s UA Systems as described herein will include the following:

- Aerial photography/video for public or private use including real estate and other related professional 

activities

- Video production and professional photography of public and private events
- Land surveying and exterior building inspections

Chair 8 Media seeks exemption to use a DJI Phantom 2 and a DJI Inspire 1 unmanned Aircraft systems. 

Under Exemption 11138 the FAA recently granted an exemption for the use of a Phantom 2 system for 

similar use. The Phantom 2 is a four rotor UA with a maximum takeoff weight of 1.3 Kg (2.86 lbs.).

While operating the DJI Phantom 2 Chair 8 Media will fly no higher than 400ft and always remain within 

visual site of the PIC. These value limits for height and radius are configured in DJI software and 

programmed into DJI Phantom 2. The max speed is 10m/s (22.3 mph) with Ascent Max at 6m/s and 

Descent at 2m/s

Under exemption No.12839 the FAA approved the DJI Inspire 1 for similar use in real estate photography 

and land survey. The DJI Inspire 1 is a four rotor unmanned Aircraft system that has a maximum takeoff

weight of seven pounds and maximum speed of 22m/s (49 mph). It is operated with similar software and 

controls as the Phantom 2. 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in reference to 49 

U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with 

both of these aircraft and their operation, the Secretary of Transportation has determined that these

aircraft meet the conditions of Section 333. Therefore it has been established that specific relief from 14 

CFR part 21, Certification procedures for products and parts, 2 Subpart H—Airworthiness Certificates, 

and any associated noise certification and testing requirements of part 36, are not necessary.

Chair 8 Media seeks exemption relief from the following CFRs listed below:

14 C.F.R. Part 21 

14 C.F.R. 45.23(b)

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

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.103(b)(2)

14 C.F.R. 91.105

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 

14 C.F.R. 91.401 -91.417

All UAS operated by Chair 8 Media will be conducted at an altitude that is below 400 feet above ground 

level and while flying at speed below 87 knots or (100 mph). While operating all UAS Chair 8 Media 

will adhere to the following additional steps to insure safety of operation:

1. Operations will be limited to the DJI Phantom 2, and DJI Inspire 1, weighing less than 55 pounds 

including payload. (Proposed operations using any other aircraft will require a new petition or an

amendment to this exemption request.)

2. No operations for the purpose of closed-set motion picture and television filming will be permitted. 
3. The UAs will not be operated at a speed exceeding 48 knots (55 miles per hour). The exemption holder 

will use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no event will the UA be operated at airspeeds greater than the maximum UA operating 

airspeed recommended by the aircraft manufacturer. 

4. The UAs will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude 

will be calculated and reported in feet AGL. 

5. The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. 

This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, 

as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of 

sight (VLOS) of the PIC and the VO at all times. The VO may be used to satisfy the VLOS requirement 

as long as the PIC always maintains VLOS capability. The VO and PIC will maintain the ability to 

communicate verbally at all times (electronic messaging or texting will not be permitted during flight 

operations). The PIC will ensure that the VO can perform the duties required of the VO.

7. The PIC will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition 

for safe operation.

8. Prior to each flight, the PIC will conduct a pre-flight inspection to determine that the UAS is in a 

condition for safe flight. The pre-flight inspection will endeavor to account for any and all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft will not be operated until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. 

9. Chair 8 Media will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components and will comply with all manufacturer 

safety bulletins. 

10. As a PIC, Chair 8 Media will employ Clark Harris, a licensed private pilot, or another pilot holding

either an airline transport, commercial, private, recreational, or sport pilot certificate. Mr. Harris holds a 

current FAA airman medical certificate. Any other pilot employed as a PIC will either hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. 

11. Any PIC employed by the operator will be required to demonstrate the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 

CFR§ 61.51(b). 

12. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR) are not authorized. 

13. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 
holder or permission granted by the airport’s flight control personnel. Any such letter of agreement with 

airport management will be made available to the Administrator or any law enforcement official upon 

request.

14. If the UAS loses communications or loses its GPS signal, the UA will be returned to a predetermined location within the private or controlled-access property as determined by the Fail Safe 

commands entered prior to takeoff. 

15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

16. 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. 

17. The UA will remain clear of and give way to all manned aviation operations and activities at all times. 

18. The UAS will not be operated by the PIC from any moving device or vehicle. 

19. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. 

20. All operations will 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. 

The exemption requested by Chair 8 Media is similar in all/or many material respects to relief previously 

requested and granted in Grant of Exemption Nos. 11062, 11109, 11112, and 11213.

In summary, Chair 8 Media is submitting this petition for exemption under Section 333, because we are 

otherwise prohibited from conducting business with our UA Systems under current law without an 

exemption granted by the FAA. The public will benefit from the grant of this exemption as a result of the 

use of safer, quieter and more environmentally conservative aircraft being utilized in our aerial 

photography and video production activities. Chair 8 Media will take every reasonable and required 

precaution to ensure the public safety while operating its UA Systems in populated areas and work sites.

Please advise me of any additional information or changes that you may require. We will greatly 

appreciate any possible efforts that you may make to expedite consideration of this request. Thank you 

very much for your attention to this matter. I look forward to your response.

Signed

Cameron Barker

Managing Member

Chair 8 Media, LLC