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