FAA Exemption Letter v. 1

Dear Sir or Madam,

Pursuant to Section 222 of the FAA Reform Act and Title 14 CFR, Philip Pitts Productions, LLC formally requests an exemption from the Federal Aviation Regulations detailed below for all current and future sUASs including the DJI S800 hexcopter, S1000 octocopter, and Inspire quadcopter.

As a video production company, using Unmanned Aircraft Systems as part of our production process allows us to increase our production capabilities. Outlined below is the general operating procedure for each flight conducted for Philip Pitts Productions, LLC in an effort to illustrate the extent of sUAS usage in our aerial and video productions.

General Operating Procedures

Arrive on site with obtained permission from the landowner and/or persons on site.

Scout general flight area to determine flight paths and safe landing areas in case of an emergency.

Remove equipment from vehicle including: copter, controls, flight manual, and any other equipment pertinent to creating a ground station and preparing for launch.

Person-in-command (PIC) performs a general inspection of equipment to ensure all is in optimum working order. Weekly maintenance inspections are performed at the office. The following is checked at both locations: all screws and fasteners, all props and motors before first flight on set, all radio receivers and transmitters are in good working order.

On site, GPS location is set and locked allowing the GPS system to adjust to traveled location.

First test flight is performed by PIC and VO away from persons/ property to ensure hover is working correctly and all commands are in proper working order.

Start flying predetermined flight paths utilizing person-in-command (PIC) and visual observer (VO).

All flights are flown to no less than 20% battery capacity. This allocates battery life for “in case of emergency” situations.

Flight times to not typically extend past 20 minutes and the sUAS does not exceed an altitude of 400 ft.A “blanket” commercial Certificate of Authorization would allow Philip Pitts Production, LLC to use the sUAS systems to support aerial photography and videography. Philip Pitts Productions, LLC requests exemptions from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV system.

Title 14CFR Part 21— Airworthiness Certificates We request an experimental certificate issued for our sUAS’s under the Research and Development provision as well ash the Showing Compliance With Regulations provision. Testing new sUAS design concepts, equipment, operating techniques, or innovative uses for the aircraft is a fundamental part of our business operations. Along with standard videography capabilities, our sUASs can be used for commercial purposes such as sales demonstrations or market surveys. Because of the light weight construction of the sUAS and the absence of passengers or fuel, we propose that our copters will be safer than conventional certified aircrafts.

Title 14 CFR 45.23 Display of Marks; 45.29 Size of Marks; and 91.9 Flight Manual, Markings and Placard Requirements.

Because of the relative size of our sUASs, we are requesting an exemption due to the lack of an entrance over which the word “EXPERIMENTAL” can be placed. We propose to attach the proper documentation, including “EXPERIMENTAL” and the registration number, on a placard on the sAUS. Secondly, since the SUASs is too small to carry the flight manual and other paper documentation, we propose to keep all pertinent information at the ground station for the PIC and VO to access upon request.

Title 14 CFR 91.7 Prohibits the Operation of an Aircraft Without an Airworthiness Certificate This regulation is inapplicable because no such certificate will be applicable in the form contemplated by the Federal Aviation Regulations.

Title 14 CFR 91.119 Minimum Safe Altitudes; 91.121 Altimeter Settings The typical use for an sUAS by Philip Pitts Productions, LLC is the photography, filming, or survey of people, vessels, vehicles, and various structures. It is necessary to operate closer than 500 ft for the items listed above. We request an exemption to the minimum safe altitudes on the grounds that any operation performed will be with permission from all parties involved and will follow a pre-planned flight path. The sUASs will operate at a low altitude at or below 400 feet AGL allowing a relatively easy landing in case of an emergency and in order to prevent conflict with other aircrafts. An AGL altimeter measurement is transmitted from the on-board computer to the display screen held by the PIC which provides a constantly accurate reading. Because of the small size of the sUASs, there is a decreased opportunity for mishaps that could potentially effect persons, structures, and vehicles. Our pilot-in-command is safety certified for the most strenuous job sites which should be considered in granting the exemption.

Title 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions Our sUASs are battery operated with a typical flight duration lasting 15 minutes with allocating 25% of the battery as a reserve. A full battery charge ensures we meet the reserve energy requirement outlined by the FARs. We request that, for our sUASs, the word energy be an equivalent interpretation for fuel.Title 14 CFR 91.203 (a) & (b) Civil Aircraft Certifications Required We request an exemption based on the inability for our sUASs to carry the appropriate documentation based on the relative size of the craft. To meet the requirements outlined by the FAA, we ensure all necessary documentation will be available at the ground station and can be produced upon request. To identify the aircraft, a placard with all pertinent information will be fixed to the sUASs.

Title 14 CFR Subpart E (91.401-91.417) Maintenance, Preventative Maintenance, and Alterations The PIC performs all necessary maintenance and inspections on the sUASs in order to “approve for return to service by a person authorized under 43.7.” The PIC ensures the sUAS in use is in airworthy condition before every flight and conducts detailed inspections after every two hours of flight. Due to the size, construction, and simplicity of the aircraft, along with having previously built custom unmanned aircraft systems, the PIC can ensure the safety of all parties involved. Maintenance by the pilot is reserved to minor repairs including: small cracks, replacing propellors, checking electrical connections, and updating software and hardware for the onboard computer, All major maintenance is performed by the manufacturer or a designated repair facility. All work will be documented and kept at the ground station.

All our sUASs have been tested and proven capable for flight by a controller. They are devices offered for sale to the general public and are operated to the strictest standards to ensure the highest level of safety. All unmanned aircraft, under authorization by the US DOT-FAA, are lightweight devices operated at or under 400 feet, with a PIC and VO in constant line of sight, with permission granted from all parties involved.

The exemption requested should be granted to Philip Pitts Productions, LLC which will permit the operations of UAS in accordance with its manuals and all other parameters that are necessary and appropriate by the FAA. The submission of this application is the soundest demonstration that some unmanned aircraft systems are used for legitimate commercial activities with the highest attention to safety. We are prepared to modify or amend any part of this exemption request to satisfy the need for equivalent levels of safety. Please contact us at any time if additional information or clarification is required.

Sincerely,

Philip Pitts Pilip Pitts Productions, LLC 205.612.7411 info@pittsmedia.com 5520 Highway 280 Suite 2 Birmingham, AL 35242