UAV Videos llc

FAA Section 333 Modernization and Reform Act of 2012 (FMRA) Request for Exemption

UAV Videos llc

Joseph M. Chonka

1016 W. Blackhawk Dr.

Phoenix, AZ 85027

(602) 653-0434

josephchonka@cox.net

Summary: UAV VIDEOS LLC seeks exemption from the federal regulation requirements of 14 CFR 

45.23(b), 14 CFR 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit UAV VIDEOS LLC to operate 

an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography for real estate promotion, non profit promotional videos multi-media presentations and 

internet based video production over certain areas of the United States.
Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from:

14 CFR 21 subpart H 

14 CFR 45.23(b) 

14 CFR 61.113(a) and (b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

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

14 CFR 91.417(a) and (b) 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, UAV Videos llc, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

designated UAS, provided such operations are conducted within and under the conditions outlined 

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

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events 

and cinematography.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers.

5. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the 

safe operation of such aircraft systems in the national airspace system.” 

I plan to operate a UAS, the DJI PHANTOM II Vision+ which is comprised of an unmanned aircraft (UA or 

Phantom II Vison+) and a transportable ground station. The DJI Phantom II Vison+ has a maximum gross 

weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, and height of 11.8 inches. 
It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 15 m/s. 

We also plan to operate a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or 

Inspire 1) and a transportable ground station. The Inspire 1 is referred to as a quad-copter with a 

maximum gross weight of about 6.5 pounds. It is equipped with four rotors that are driven by electric 

motors powered by batteries. The UA has a maximum airspeed of 22 m/s. 

Also, given the small size of the UAS’s involved and the restricted controlled environment 

within which they will operate, the applicant fits within that zone of safety (an equivalent level 

of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs and the 

controlled areas in which the relevant UASs will operate, approval of the application presents 

no national security issue. Given the following, the grant of the requested exemptions is clearly in the 

public interest: 

UAV Videos llc proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations listed herein. These limitations provide 

for an exceptional level of safety to operations. These limitations and conditions to which UAV 

VIDEOS llc agrees to be bound when conducting commercial operations under an FAA issued 

exemption including: 

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes.

4. Flights will be terminated at 15% battery power reserve.

5. Flights will be operated at an altitude of no more than 400 feet AGL.

6. UAS operator will be trained and certified in the proper safety and operations of the UAS.

7. The UAS will only operate within a controlled area as defined in the operating procedures.

8. The operator will post advisor notices around the controlled area.

9. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required.

10. If the UAS loses communications to the ground station, the UAS will have capability to return to 

a pre-determined location within the security perimeter and land.

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

12. Flights will be operated during daylight hours only.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption 

and are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. We look forward to working with your office. Please contact us at 

any time if additional information or clarifications are needed.

Sincerely, 

Joseph M. Chonka

(602) 653-0434

UAV VIDEOS llc