FRONT SIDE FILMS

3919 Brace Ranch Road

Loomis, California 95650

February 12, 2016

Docket Operations, M-30

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition for Exemption under FAA Modernization and Reform Act of 2012 (P.L. 112-95),

 Section 333

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(FMRA) and 14 CFR

Part 11, Front Side Films hereby applies for an exemption from Federal Aviation Regulations 

(FARs) listed below under “Basis for Petition” and discussed in Appendix A. Exemption is 

being sought in order to allow Front Side Films to operate its unmanned aircraft systems (UAS) 

commercially for the purpose of aerial videography and photography, precision agriculture and 

environmental management, scientific analysis and research, surveying, aerial inspection of land 

and structures, search and rescue and emergency services, journalism and news gathering, real 

estate marketing, and television and film making and production. 

INTRODUCTION OF THE PETITIONER

Front Side Films will provide services to its clients to enhance a variety of their business and 

personal objectives by providing digital photography, videography, data acquisition, cinematic 

consulting and other types of digital imaging and related services. The principal members of the 

organization possess over 8 years of experience in aviation, in both unmanned fixed-wing r/c and

rotorcraft UAS piloting as hobbyists, amassing more than 500 hours of flight time as pilot-incommand of numerous airframes for personal uses. The principal owner of Front Side Films, Mr.

Damon Chamberlain, is a long-time member of the Academy of Model Aeronautics and is 

particularly active in the Sacramento, California AMA chapter. Mr. Chamberlain and his team are

experienced photography, film and video professionals with experience in photographic and 

video technology, equipment, methodologies and business operations. In addition to and varied 

aviation experiences with UAS, the members of Front Side Films are skilled in the areas of 

ground-based photography, videography, photo and video editing, and consulting services. The
objective of Front Side Films is to provide professional quality digital imaging, aerial data 

acquisition, editing and analysis for a variety of commercial, public, private and not-for-profit 

organizations and individuals, including, but not limited to:

- Motion picture and television filming and production 

- Photography and videography for journalism and news gathering purposes

- General aerial photography, including inspection of structures and construction sites

- Aerial image and data acquisition for search and rescue and other emergency situations

- Real estate marketing photography and videography 

- Digital imagery and data acquisition for precision agriculture, environmental management, 

surveying, and scientific analysis and research

- Aerial photography and videography of landscapes and outdoor adventures 

UNMANNED AERIAL SYSTEMS

DJI Phantom 3 Professional, DJI Inspire 1 and Freefly Systems ALTA 

Front Side Films seeks an exemption to operate DJI Phantom 3 Professional, DJI Inspire 1 and 

Freefly Systems ALTA unmanned aerial systems (UAS) for compensation or hire within the 

National Air Space (NAS). The DJI Phantom 3 Professional, DJI Inspire 1 and Freefly ALTA are 

vertical takeoff and landing (VTOL) unmanned aircraft. The DJI Phantom 3 Professional is a 

four-rotor quadcopter that has a maximum gross weight of approximately 3 pounds 3 ounces, 

including DJI X3 gimbal camera systems, and a maximum speed according to the manufacturer 

of approximately 33.5 miles per hour. The DJI Inspire 1 is a four-rotor quadcopter that has a 

maximum gross weight of 6 pounds 7.5 ounces, including onboard gimbal and camera systems 

and batteries, and a maximum speed of approximately 48.5 miles per hour. The Freefly Systems 

ALTA is a six-rotor hexacopter that has a maximum allowable weight according to the 

manufacturer of 30.0 pounds including batteries ,gimbal and a variety of high definition digital 

camera systems, and a maximum speed of approximately 40 miles per hour. Each of the abovedescribed UAS are equipped with rotors and propellers driven by lithium polymer battery 

powered electric motors .Each are also equipped with the industry standards in GPS, electronics, 

guidance, propulsion, telemetry, safety features and ease of operator functionality. Detailed 

information regarding each UAS is attached to this petition as Appendices B, C and D.

It should be noted that these particular UAS have each been approved in connection with prior 

Section 333 grants of exemption. Specifically, the DJI Phantom 3 Professional was the UAS 

identified by the petitioner in Exemption 11906 (and others); the DJI Inspire 1in Exemption 

11280 (and others); the Freefly Systems ALTA in Exemption 12634 (and others). Each UAS is 

recognized in the UAS industry as a leading example of precision, quality, performance and 

durability and technological innovation. The UAS will offer Front Side Films a range of options 

for matching the desired flight characteristics and technology with the desired tasks, 

environmental conditions, and navigational demands, thus assuring overall safety and completion

of assigned work product and desired results. 

BASIS FOR PETITION
Front Side Films, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

Section 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Phantom 3 Professional ,DJI Inspire 1, and Freefly Systems ALTA 

UASs in the national airspace system (NAS), and for an exemption from the requirements of 14 

C.F.R. Sections 61.113(a) & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b). 

The granting of exemption from the above-listed FARs will allow Front Side Films to conduct 

commercial operations of its UAS to efficiently and safely deliver high-definition digital imagery

and other acquired data to its clients and customers more cost-effectively than traditional 

methods. Employing UAS technology can also be safer for workers because in many instances 

the workers may avoid dangerous or precarious hazards or physical positions involving high risk 

of injury. Unmanned aerial systems also enable safe inspection of difficult to reach or 

environmentally sensitive locations without the use of heavy trucks, cranes, booms or other 

equipment requiring greater expense or attendant undesirable environmental impacts. In general, 

UAS operated by Front Side Films will economically benefit their customers by acquiring 

important and aesthetic digital imagery and data safely and less expensively for a wide variety of

applications. 

Front Side Films proposes to use UAS that are multi-rotor craft weighing a maximum of 30.0 

pounds fully loaded, or less, which fly at a speed of 48.5 miles per hour, or less. The craft are all 

equipped with built-in safety features including sophisticated navigation controls and fail-safe 

technology to assure safe and predictable aerial maneuvers, take-off and landing. Proposed 

operations will be conducted under controlled conditions in airspace that is limited, 

predetermined, access controlled and under constant monitoring before and during flight.

Operations contemplated under the exemption will be subject to strict operating parameters to 

ensure at least an equivalent level of safety to currently authorized and/or exempted operations.

NAME AND ADDRESS OF THE PETITIONER

The name and address of the Petitioner and point of contact is: 

Front Side Films 

Attn: Damon Chamberlain

3919 Brace Ranch Road

Loomis, CA 95650

(916) 712-4465

Email: damonchamberlain@hotmail.com

OPERATING DOCUMENTS

The comprehensive operations manuals/user guides/safety guides and other detailed information 

provided by the UAS manufacturers are attached to this petition as Appendix “B” (DJI Phantom 

3 Professional), Appendix “C” (DJI Inspire 1) and Appendix “D” (Freefly Systems ALTA). The 
appendices are comprehensive and current for each UAS, and offer a complete description of 

each aircraft, including operating features and protocols, specifications, maintenance 

recommendations and guidance, safety and navigation information, battery maintenance and 

safety, aircraft controls and gimbals, and more.

Attached as Appendix “E” is Front Side Films Pre-flight Checklist and In-flight safety checklist; 

Appendix “F” contains Front Side Films UAS Flight Log Form and Front Side Films Monthly 

Maintenance and Inspection Log Form.

THE PILOT IN COMMAND (PIC)

The PIC will:

- Hold a current FAA sport pilot certificate or higher FAA pilot certification

- Hold a valid third-class medical certificate

- Have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of

25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot 

with similar UAS type

- Have accumulated and logged a minimum of five hours as a UAS pilot with the make and 

model of UAS to be utilized for operations under the exemption and three take-offs and 

landings in the preceding 90 days prior to an operation 

- As noted below in “Operating Parameters, Limitations, Conditions and Requirements”, the 

operator will not allow a PIC to operate unless the PIC has demonstrated that the PIC is able

to safely operate the UAS in a manner consistent with how the UAS will be operated under 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Visual observers must have demonstrated that they understand the conditions and limitations of 

flight noted in the same section which follows immediately below.

OPERATING PARAMETERS, LIMITATIONS, CONDITIONS AND REQUIREMENTS

Grant of the exemptions will be subject to the following conditions, which provide at least an 

equivalent or higher level of safety than under the current conditions. These conditions are 

derived from Exemptions 11062 through 11067, 11080, 11109 and 11110, and others.

For the following listing, the Petitioner, Front Side Films is referred to as the operator.

1. Operations authorized by the grant will be limited to the UAS described above and 

manufacturers’ upgraded versions.
2. The UAS weigh 30.0 pounds or less, including batteries, gimbals, camera systems and 

other necessary attachments.

3. The UA will be flown at a maximum ground speed of 40 miles per hour. In no case will a 

UA be operated at airspeeds greater than the maximum UA airspeed recommended by the

aircraft manufacturer. 

4. The UA will be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the 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 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 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 be able to communicate verbally at all times. Electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated before 

the flight and will not transfer his or her designation for the duration of the flight. The 

PIC will ensure that the VO can perform the functions duties required of the VO.

7. The operating documents and the grant of exemption will be accessible during UAS 

operations and made available to the Administrator upon request. The operator may 

update or revise its operating documents. It will be the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator or any 

law enforcement official upon request. If there is a discrepancy between the exemption 

conditions and limitations and the procedures outlined in the operating documents, the 

conditions and limitations in the grant of exemption take precedence and will be 

followed. Otherwise, the operator will follow the procedures outlined in its operating 

documents. If the operator determines that any update or revision would affect the basis 

upon which the FAA may grant this exemption, the operator will petition the FAA for 

amendment to the exemption.

8. Any UAS that has undergone maintenance or alterations that affect the UAS flight 

characteristics or operation, e.g. replacement of an essential flight component, will 

undergo a functional test flight prior to conducting further operations. Functional test 

flights will be conducted by a PIC with a VO and will remain at least 500 feet from other 

people. The functional test flight will be conducted in such a manner so as not to pose an 

undue hazard to persons and property.

9. The operator will be responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation.

10. Prior to each flight the PIC will conduct a pre-flight inspection and determiner that the 

UAS is in a condition for safe flight. The pre-flight inspection will account for 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 

be prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight. 

11. The operator will follow the UAS manufacturers’ maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under the exemption will comply with all manufacturer safety 

bulletins. 

13. The PIC will possess at least a private pilot certificate and a current third-class FAA 

airman medical certificate. The PIC will also meet the flight review requirements 

specified in 14 CFR 61.56.

14. The operator may not permit any PIC to operate unless the PIC has demonstrated that the 

PIC is able to safely operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distance from people, vessels, vehicles and structures. PIC 

qualification flight hours and currency will be logged in a manner consistent with 14 CFR

Section 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PICs ability to safely

operate the UAS in a manner consistent with how the UAS will be operated under the 

exemption will be permitted under the terms of this exemption. However, training 

operations will only be conducted during dedicated training sessions. During training, 

proficiency and experience-building flights, all persons not essential for flight operations 

are to be considered non-participants, and the PIC will operate the UA with appropriate 

distance from non-participants in accordance with 14CFR Section 91.119 

15. UAS operations will not be conducted during night, as defined in 14 CFR Section 1.1. All

operations will be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) will not be conducted.

16. 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 aeronautical chart

published by the FAA, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management will be made available to the Administrator or 

any law enforcement official upon request.

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location or recovery point within the private or controlled-access property.
19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. 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 still 

maintain a reserve battery power of no less than 25%.

21. The operator will apply for and obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations under 

the grant of exemption.

22. All aircraft operated in accordance with the exemption will be identified by serial number

or equivalent, registered in accordance with 14 CFR part47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as 

large as practicable. 

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

any documents required under 14 CFR Sections 91.9 and 91.203 will be available to the 

PIC at the Ground Control Station of the UAS at any time the aircraft is operating. These 

documents will be made available to the Administrator or any law enforcement official 

upon request.

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

all times.

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

26. All flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect non-participating persons 

from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations will cease immediately in a manner ensuring the safety of non-participating 

persons; and, 

b. The owner/controller of any vessels, vehicles, or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons will not be considered nonparticipating persons under the exemption.

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

permission from the land owner/controller or authorized representative. Such permission 

will be obtained for each flight.

28.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 (AFS-80) within 24 hours. Accidents will be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

THE PUBLIC INTEREST

The public interest in granting this exemption request is served by, among others, the following:

- The use of UAS improves public safety and reduces risk by alleviating the public‘s 

exposure to danger and emissions associated with conventional aerial methods (full size 

aircraft) that are very heavy, fast and carry passengers, flammable fuel and cargo.

- A myriad of ecological and environmental benefits and improved economic efficiency and 

scientific information and data acquisition are potential public benefits accomplished 

through the use of UAS for precision inspections of infrastructure and industrial plant and 

equipment such as energy pipelines, power lines, smokestacks, towers, and other man-made

structures, which can be observed and later analyzed safely, accurately and unobtrusively. 

- Commerce can be improved through data and image acquisition for real estate, construction,

precision agriculture, surveying and other applications of UAS technology.

- The visual arts such as film, photography and television are improved through exciting and 

beautiful images captured via the versatile aerial platform UAS provides, which benefits the

collective cultural and aesthetic demands and desires of an appreciative public.

- UAS may be an exceptional tool for journalists and all manner of news gathering and 

reporting media, to serve the public good in enhancing accurate dissemination of 

newsworthy and relevant information to interested citizens.

- Approval of this exemption will provide immediate employment opportunities for 

individuals and businesses whose livelihood may be directly or indirectly improved through

career opportunities and job creation in a growing technology sector of the economy.

- Congress has established a national policy that favors prompt integration of UAS into the 

NAS, provided that judicious and reasoned agencies and officials guide the process 

prudently and with due emphasis on public safety and efficiency. The granting of this 

Petition for exemption will serve this public policy mandate and result in the attendant 

benefits perceived by this policy.

SUMMARY FOR PUBLICATION

For publication in the Federal Register, Front Side Films provides this summary:

An exemption is requested from the following regulations in order to allow commercial 

operation of its Unmanned Aircraft Systems involving aerial applications such as general aerial 

photography and videography, motion picture and television photography ,aerial photography of 

landscapes and outdoor adventures, aerial imagery for inspection of structures, construction 

projects and real estate, videography and photography for journalism and news gathering 

purposes, digital imagery and data acquisition for search and rescue operations, precision 

agriculture, environmental management, and scientific analysis and research.
14 CFR Section 61.113 (a) and (b)

14 CFR Section 91.7(a)

14 CFR Section 91.119(c)

14 CFR Section 91.121

14 CFR Section 91.151(a)(1)

14 CFR Section 91.405(a)

14 CFR Section 91.407(a)(1)

14 CFR Section 91.409(a)(1) and (a)(2)

14 CFR Section 91.417(a) and (b)

CONCLUSION

Front Side Films seeks an exemption, pursuant to 14 CFR Section 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit Front Side Films to 

safely operate UAS commercially for the purposes and operations described herein. In granting 

this Petition, the FAA Administrator will be fulfilling the Congressional mandate and policy of 

FMRA, while also providing a significant number of benefits to the public, the environment and 

the economy. The exemption will enable Front Side Films to utilize its aviation experience, 

technological expertise, advanced aircraft, and entrepreneurial vision to enhance the safety, 

beauty and economic progress of the public and private sectors and advancing the interests of 

society at large.

Front Side Films respectfully requests that the Administrator grant this Petition for an exemption 

from the requirements discussed herein, and permit Front Side Films to operate commercially the

unmanned aircraft systems in the aerial operations set forth herein.

Thank you for your consideration.

Sincerely,

Damon Chamberlain

Front Side Films

APPENDIX A
14 CFR Section 61.113(a) and (b); Private Pilot Privileges and Limitations: Pilot in 

Command; Commercial Pilot Privileges and Limitations

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Section 61.133(a) 

requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for 

compensation or hire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, 

the UAS proposed for use by Front Side Films are remotely controlled with no passengers or 

cargo on board.

Front Side Films respectfully requests exemption from these requirements based on the particular

characteristics of the UAS that will be used. The risks associated with the operation of the UAS 

described above (given the size, weight, airspeed, operational characteristics and lack of 

combustible fuel) are much lower than the risks associated with commercial operations 

contemplated by Part 61 with conventional manned aircraft. Accordingly, a private pilot, 

adequately trained in the proper use of UAS, possesses the requisite skills and knowledge of the 

NAS and FAA regulations to assure the safe operation of the UAS. In addition, Front Side Films 

will operate the identified UAS with a high degree of control and a number of built-in technical 

capabilities that serve to strictly limit the potential for operation outside of the operating 

conditions and restrictions set forth in this Petition.

Front Side Films emphasizes and requires UAS training and flight experience for those PICs who

will operate these aircraft in the proposed commercial applications. By requiring extensive flight 

experience with these aircraft (multirotor UAS) in general, and with each specific make and 

model of the UAS to be utilized for operations under the proposed exemption, the Front Side 

Films PICs will possess greater knowledge of and experience with the UAS than they would by 

holding a commercial pilot license for an entirely different type of airborne system.

Given the inherently lower-risk nature of the UAS and these training and experience 

requirements and UAS safety features and operational safeguards, Front Side Films proposes and

requests that PICs should not be required to hold a commercial pilot certification. Instead, PICs 

should be required to hold a current private pilot certification and have the experience with UAS 

as indicated in this Petition.

The risks associated with the operation of the UAS identified herein (considering their size, 

weight, airspeed, operational characteristics, and absence of combustible fuel) are so diminished 

from the level of risk associated with commercial operations contemplated by Part 61 with 

conventional aircraft (rotorcraft or fixed wing) that allowing operations of the UAS as set forth 

above meets or exceeds the present level of safety provided under 14 CFR Section 61.113(a) and 

(b) and does not rise to the level of requiring a commercial pilot to operate under 61.113(a).

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the UAS identified herein with a private pilot’s certificate, under the 

conditions set forth in this Petition. The FAA has granted exemption to conduct similar 

operations in Exemptions 11062 through 11067, 11080, 11109 and 11110.
14 CFR Section 91.7(a): Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the named aircraft

without an airworthiness certificate, no standard will exist for the airworthiness of the aircraft. 

Given the size of the aircraft and the requirements that the operator has agreed to as relates to 

airworthiness, as set forth herein and in the various operating documents, an equivalent level of 

safety will be achieved by ensuring compliance with the aircraft manuals and operating 

documents for each flight. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080, 11109 and 11110.

14 CFR Section 91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civilian aircraft. Section 91.119(c) 

prohibits operations below 500 feet above the surface, or closer than 500 feet to any person, 

vessel, vehicle or structure. As this exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. The equivalent level of safety will 

be achieved given the size, weight and airspeed of the UAS as well as the location where it will 

be operated. No flight will be taken without the permission of the property owner or local 

officials, where required. Because of the advance notice to the property owner and participants, 

all affected individuals will be aware of the planned flight operations as set forth in the plan of 

operations. Front Side Films therefore requests a waiver from Section 91.119(c) for all 

participating persons, i.e. persons associated with the operations.

Front Side Films will also ensure that non-participating persons are kept at least 500 feet from 

the operating area, or seek approval from the Administrator for less separation if an equivalent 

level of safety can be achieved. Compared to flight operations with conventional aircraft or 

rotorcraft weighing far more than the maximum 30.0 pounds proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those risks associated 

with the conventional craft. In addition, the low-altitude operations of the UAS will ensure 

separation between these UAS operations and the operations of any conventional aircraft that 

must comply with Section 91.119. The FAA has granted exemptions to conduct similar 

operations in Exemptions 11062 through 11067, 11080, 11153, and 11159. 

14 CFR Section 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out or display, an exemption may be needed. An equivalent level 

of safety will be achieved by the operator confirming the acquisition of GPS signals and an 

initial ground level altitude of zero prior to take-off. The FAA has granted exemptions to conduct

similar operations in Exemptions 11062 through 11067 and 11080.

14 CFR Section 91.151(a): Fuel Requirements for Flight in VFR Conditions
Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery(ies) powering the named UAS rotorcrafts provide approximately 20-25 minutes or 

less of powered flight, depending upon overall flight conditions. To meet the 30 minute reserve 

requirement in 14 CFR Section 91.151, UAS flight would not be practicable or effective. Front 

Side Films believes that an exemption from 14 CFR 91.151(a) is safe and falls within the scope 

of prior exemptions.

Operating the UAS in a controlled area with a limitation on the flight upon reaching 25% of 

battery power does not engender the type and magnitude of risks that 91.151(a) was intended to 

alleviate given the size and airspeed of the UAS. Front Side Films believes that an equivalent 

level of safety can be achieved in this manner. This restriction would be more than adequate to 

return the UAS safely to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted by the FAA to other Petitioners, including exemptions 

11062 and 11159.

14 CFR Sects. 91.405(a); 407(a)(1); 409(a)(1)and(2); 417(a)and(b):Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in Subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Front Side Films. Maintenance will be accomplished by Front Side 

Films pursuant to Front Side Films’ operations manuals and practices along with manufacturer 

specifications. An equivalent level of safety will be achieved because these small UAS are very 

limited in size ( no more than 30.0 pounds), will carry a small payload and operate only in 

restricted areas for limited periods of time with no flammable fuel. If mechanical issues arise the 

UAS can land almost immediately, and furthermore will be operating from no higher than 400 

feet AGL.

As provided herein Front Side Films will ensure that the UAS is in proper working order prior to 

initiating flight, perform a preflight operational and safety checklist, perform required 

maintenance, and keep a log of any maintenance performed. Furthermore, Front Side Films is 

most familiar with the UAS and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. The FAA has granted these exemptions to conduct similar 

operations in Exemptions 11228, 11241 and 11251.