300 S Wells Ave Ste 7A

E-mail: ruta@ambershorepictures.com

Website: www.ambershorepictures.com

Phone: (206) 393-7778

Date: March 4th, 2016 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Petition of Amber Shore Pictures LLC for Exemption Pursuant to Section 333 of 

the FAA Reform Act 

Attn: To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Amber Shore Pictures LLC, operator of small 

unmanned aircraft systems (“sUAS”) equipped to conduct aerial photography and 

videography, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAS, so long as such 

operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.1. 

As described more fully below, the requested exemption would permit the operation 

of small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed 

exemption, if granted, would allow Amber Shore Pictures LLC to conduct commercial 

operations of small unmanned aircraft systems (“sUAS”) meeting or exceeding all of 

the operational and safety requirements Congress has set forth in Section 333. 
Amber Shore Pictures LLC is a media company that plans to exploit the capabilities 

of unmanned aerial systems to offer a multitude of photography and videography 

services, including:

● Residential and commercial real estate

• Web and commercial videos

● Nature & wildlife 

● Wedding videography

● Special events 

● Surveying and mapping 

● Golf courses 

● Educational and research applications

Statutory Authority

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a 

mechanism for seeking expedited FAA authorization of safe civil sUAS operations in 

the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system before completion 

of the (comprehensive) plan and rulemaking required by section 332 (b) (1) of this Act 

or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress 

made it clear that Section 333 provides a mechanism for “expedited operation 

authorization” if several factors are met. Petitioner meets all requirements to permit 

FAA approval of commercial sUAS operations. 
The Petitioner Requests Relief From the Following: 

Regulations from which the exemption is requested: 

● 14 C.F.R. Part 21 

● 14 C.F.R. 45.23 (b) 

● 14 C.F.R. 61.113(a) and (b) 

● 14 C.F.R. 91.7 (a) 

● 14 C.F.R. 91.9 (b) (2) 

● 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)

Unmanned Aircraft System sUAS are oftentimes seen as superior to helicopters due to 

the smaller devices cheaper equipment and personnel cost, reduced noise and as such, 

a much smaller environmental impact which promotes public safety. 

We are petitioning for exemption to enable Amber Shore Pictures LLC to operate a 

Yuneec Q500 which is equipped with a gimbal and HD camera. This sUAS has a builtin capability to limit the height it flies above the ground, to limit the radius of the 

distance it flies from the operator and to exclude it from Class B, C and D airspace 

including a no fly zone feature. The Q 500 also has the failsafe function of autopilot 

system, which means that if the communication between the main controller and the 

transmitter is disconnected the system will automatically trigger “Return to Home” 

and land safely. The above specifications meet with the Model Aircraft Operating 

Standards as set below:

● Amber Shore Pictures LLC will only operate its sUAS in line of sight of a pilot and/

or observer and will operate at sites that are a 'sufficient distance' from populated 

areas within the sterile area described in the FOPM. Such operations will insure that 

the sUAS will not create a hazard to users of the national airspace system or the 

public.
● When flying sUAS within 5 miles of an airport, airport operators will be notified and 

the operator will give the right of way to avoid flying in the proximity of full-scale 

aircraft. 

● Maximum flight time for each operational flight will be 30 minutes. 

● Flights will be terminated at 25% battery power reserve should that occur prior to 

the 30 minute limit. 

● The sUAS will be programmed so that it will not be operated at an altitude of no 

more than 400 feet AGL, and not more than 200 feet above an elevated platform from 

which filming is planned. 

● Minimum crew for each operation will consist of the sUAS pilot and visual observer. 

● The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal). 

● The sUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety 

requirements. The sUAS, powered by batteries, is smaller, lighter and more 

maneuverable than larger aircraft running on combustible fuel, it operates at lower 

altitudes with no people on board and will thereby reduce current risk levels and 

thereby enhance safety and diminish the likelihood of death or serious bodily injury. 

With a small payload and maximum flight time of only 30 minutes, this offers little or 

no risk to national security. Low level oblique photos and video from several angles 

are far more effective than ground based imagery for displaying the characteristics of 

large, complex properties with several buildings and large trees. The benefits of 

reduced cost and improved quality of presentation from the sUAS will be valuable to 

and benefit many buyers and sellers of real estate property. 

Amber Shore Pictures LLC will remain a subject to all limitations cited in this 

application.

A. No flight will be made with a Gross weight exceeding 55 pounds; 

B. All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at 

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; 

C. All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 
D. Operations will be restricted to flights over private property with the permission of 

the property owner; 

E. All required permits will be obtained from state and local government prior to 

operation; 

F. Amber Shore Pictures LLC will not be operate over densely populated areas; 

G. Amber Shore Pictures LLC will not be operating over any open-air assembly of 

people; 

H. Amber Shore Pictures LLC will not be operating over heavily trafficked roads; 

I. Amber Shore Pictures LLC will not be operating within 5 NM of an airport or 

heliport; 

We respectfully request exemption under Section 333 to enable Amber Shore Pictures 

LLC to operate efficient, limited, low-risk commercial sUAS operations for the 

activities stated respecting at all times the space and privacy of citizens and property 

whilst keeping our skies safe. 

Sincerely, 

Ruta Ilciukaite

Amber Shore Pictures LLC 

300 S. Wells Ave Ste 7A

E-mail: ruta@ambershorepictures.com 

Website: www.ambershorepictures.com 

Phone: (206) 393-7778

_______________________________________
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Amber Shore Pictures LLC requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the 

sUAS System:

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for unmanned 

aerial systems, we request an experimental certificate be issued for the Yuneec Q500 

under either or both of the following provisions: 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. The regulation provides that no 

person that holds a Private Pilot certificate may act as Pilot in Command (PIC) of an 

aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as PIC 

of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. Our proposed operations require 

that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since 

the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to 

ensure that flight manual information is available to the aircrew while operating the 

aircraft. We request an exemption to this requirement since the aircraft is not only too 

small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 
91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests.The regulation states that "No person may operate a civil aircraft that is being 

used for flight instruction unless that aircraft has fully functioning dual controls." The 

sUAS System ground-based control station consists of a small hand-held radio 

transmitter and while it does not offer a second set of "controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both 

student and instructor having "hands-on" the controls during flight, we feel that this 

technique meets the intent 91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. Since the typical mission of the sUAS would be 

photography or survey of persons, vessels, vehicles or structures it would be necessary 

to operate closer than 500 feet to the items listed. Operations will only be flown over 

property or persons where permission has been obtained and careful pre-planned has 

been performed. The aircraft will be operated at a low altitude allowing, if a power unit 

fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore we maintain that due to the small size of the sUAS, the hazard to 

persons, vehicles and structures is minimal compared to manned aircraft, which 

should be considered in granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain 

cruising altitudes by reference to an altimeter setting available within 100 NM of the 

aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground 

Level altimeter measurement above the takeoff point is transmitted via radio from the 

sUAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation 

provides that no person may begin a flight in an airplane under day-vFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after 
that for at least 30 minutes. We feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The sUAS is battery operated 

and the maximum duration of flight from a single battery charge is 12 minutes with a 

20% reserve. Since the aircraft will never fly more than 3f4 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve 

energy requirement of this paragraph. We request an exemption to the word "fuel" 

and ask for an equivalent interpretation with the word “energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides 

that an airworthiness certificate, with the registration number assigned to the aircraft 

and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." At a maximum gross weight of 3 

pounds, the sUAS is too small to carry documentation, does not have an entrance, and 

is not capable of carrying passengers or crew. To obtain an equivalent level of safety 

and meet the intent of 91.203, we propose that documents deemed appropriate for this 

aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose that 

the information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard containing the following information. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations. The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with part 39 

and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return 

to service by a person authorized under 43.7" after maintenance and inspection. It is 

our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition conduct 

detailed inspections after every two hours of flight. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and firmware for the 

on-board computer. All other maintenance will be performed by the manufacturer or 

their designated repair facility. The PIC will document work performed in accordance 
with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, 

the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the sUAS 

Amber Shore Pictures LLC will be using the sUAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, 

unmanned aerial vehicles offer myriad benefits over the use of full-sized manned 

aircraft for electric power line inspection, oil/gas pipeline inspection, advanced 

agriculture, film and still photography, just to name few. Replacing significantly larger 

manned aircraft carrying crew and flammable fuel with sUAS carrying no passengers 

or crew creates a much greater margin of safety for the pilots and crew. 

By granting Amber Shore Pictures LLC’s requested exemptions, the FAA will help 

drive development of safe and successful commercial sUAS operations and will 

advance the public knowledge base for such operations. Amber Shore Pictures LLC is 

committed to promoting the sUAS research efforts of policymakers including the FAA, 

NASA, DOD and DARPA by sharing data from its commercial sUAS operations and 

serving as a resource for future sUAS research operations. Thus, the FAA has good 

cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the sUAS which our company would use, under 

authorization by the US DOT-FAA, are small, lightweight devices operated within the 

line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location 

with aviation activities, unless the air traffic control authorities (ATC) have been 

notified and have authorized each flight within a radius of this distance.

All our sUAS have proven capability for controlled flight. They are devices offered for 

general sale on the market around the world and have often been used as Model 

Aircraft in the USA. We are certain that the studies conducted until now by the FAA, 

about Section 332, Public Law 112-95, 2014, have already provided you with the 

assurances on the airworthiness of sUAS such as ours. 
For the foregoing reasons, the exemptions requested herein should be granted and 

Amber Shore Pictures LLC should be permitted to conduct sUAS operations in 

accordance with its manuals and all other operating parameters deemed necessary and 

appropriate by the FAA. The submission of this application and its contents is the best 

demonstration that indeed it is possible to pursue the authorization process so that 

some sUAS may be used for legitimate commercial activities and under reasonably 

safe conditions. 

300 S Wells Ave STE 7A

E-mail: ruta@ambershorepictures.com 

Website: www.ambershorepictures.com 

Phone: (206) 393-7778