Carolyn Yamazaki, Esq.

Counsel

Phone: 323.644.6144 x227

Email: cyamazaki@authentictv.com

October 9, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation 

Regulations

To: Whom it May Concern:

This petition for exemption is being filed by Production Support Services, LLC (“PSS”), 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”). PSS, a 

camera equipment rental and broadcast technology company which utilizes aerial filming and 

photography for documentary and unscripted television programs, seeks exemption from the below 

listed Federal Aviation Regulations to permit the commercial operation of its Unmanned Aircraft 

Systems (“UASs”) (all such UASs are more fully described in section I. below) provided that the 

operations are conducted only according to that which is provided in this petition for exemption, or as 

may be currently or in the future required by the FAA as found in Section 333, or any other prevailing 

federal regulations. 

PSS’ petition for exemption serves to provide Congress with an opportunity to pass Section 

333 (a) – (c) of the Reform Act and to assist the Secretary of Transportation (“SOT”) in determining 

which UASs are neither a danger to the public, nor present the potential to threaten the national 

security of the United States. If the SOT determines that “certain unmanned aircraft systems may

operate safely in the national airspace system, the Secretary shall establish requirements of the safe 

operation of such aircraft in the national airspace system.” Id. § 333(c). The following factors should 

be considered in such determination: 

• The size, weight, speed, and operational capacity of the UASs

• Operation of the UASs in close proximity to airports and populated areas; and

• Operation of the UASs within visual line of sight of the operator (VLOS)
PSS seeks exemption from the following:

• 14 CFR § 21

• 14 CFR § 45.23(b)

• 14 CFR § 61.315 (b) and (C)

• 14 CFR § 61.101 (e), (a) and (b)

• 14 CFR § 61.113(a) and (b)

• 14 CFR § 91.7(a) and (b)

• 14 CFR § 91.9

• 14 CRF § 91.103

• 14 CFR § 91.109

• 14 CFR § 91.119

• 14 CFR § 91.121

• 14 CFR § 91.151(a)

• 14 CFR § 91.203

• 14 CFR § 91.405

• 14 CFR § 91.407(a)(1)

• 14 CFR § 91.409 (a)(2)

• 14 CFR § 91.417(a) and (b)

The name and address of the applicant is:

Production Support Services, LLC

2860 North Naomi Street

Burbank, California 91504

Counsel: Carolyn Yamazaki, Esq.

As further outlined below, PSS’ request for exemption would allow the operation of small 

UASs under established preset conditions that 1.) are narrow in scope, 2.) are pre-planned and predetermined, 3.) are access controlled, and 4.) improve upon the current safety operations of 

commercial filming (using a traditional manned helicopter for aerial shots). The approval of this 

petition would improve all around safety and control of the operation of UASs in the national airspace 

system.

I. UAS DESCRIPTION

PSS seeks to have this exemption cover the following UASs:

2014 UAV DJI Inspire 1

Weight: 6.57 lbs.

Max Speed: 22m/s

No. of rotors: 4

Battery type: LiPo

2014 UAV DJI Phantom 1

Weight: 2.64 lbs.

Max Speed: 10m/s

No. of rotors: 4

Battery type: LiPo
The relevant UASs potentially covered by this petition are well under the weight and speed 

limits set for vehicles to qualify for exemption under Section 333.

II. SAFE OPERATIONAL PRACTICES

PSS agrees to abide by the following limitations and conditions proposed under Part 107 of 

Title 14 Code of Federal Regulations for commercial UAS operations conducted under a granted FAA 

exemption: 

• UASs shall weigh under 55 lbs.

• The UAS shall at all times be operated under the VLOS of the operator and/or visual 

observer

• At all times the UAS shall remain close enough to the operator for the operator to be 

cable of seeing the UAS with vision unaided by any device other than corrective lenses

• UAS shall not operate over any persons not directly involved in the operation

• UAS shall only be operated in day-light hours

• UAS will yield right-of-way to other aircraft, manned or unmanned

• UAS will always be operated well under the maximum airspeed of 100 mph

• UAS will always be operated well below the maximum altitude of 400 feet

• UAS will never be operated in weather visibility of less than 3 miles from control 

station

• The UAS operator will never operate more than 1 UAS at a time

• UAS operator will at no time operate the UAS in a careless and/or reckless manner

• UAS operator will perform a preflight inspection prior to each and every flight

• UAS will not be operated with battery power below 30%

• The UAS operator will have at least 25 hours operating UAS

• No UAS shall be operated within 5 miles of the center of an airport

• UAS shall not be operated in areas that do not have the consent of the property owners

• In case of emergency, loss of communication, or other malfunction, the UASs are preset 

through GPS locators to be able to return to a pre-specified location in a safe manner.
III. EXTENT AND REASON FOR RELIEF

The UASs described above in provision I. are popular hobbyist and commercially used 

UASs. Both are telemetry systems with multiple backup and safety functions. The safety practices are 

listed supra in provision II., and further described in the UAS SAFETY PRACTICES, attached hereto 

as Exhibit A and incorporated herein. PSS is seeking exemption from a select number of regulations 

(further detailed below in section V) particularly those pertaining to airworthiness certification. 

If granted, an exemption, would allow PSS to lead the way in safety and public awareness. 

Currently, there are multiple companies operating UAS without the proper COAs and/or exemptions. 

By going through the proper channels, PSS would establish a precedent that other similarly situated 

companies would follow. 

IV. PUBLIC INTEREST

As stated in the foregoing, granting the requested exemption would set an example for other 

camera, technology and production companies that also operate UAS devices. By submitting this 

petition, PSS is taking an active role in pushing Congress to establish rules and regulation in order to 

create safety guidelines for companies and individuals to follow.

PSS currently employs well-trained and established camera operators, all of whom are leaders 

in their industry. With the inclusion of safe and regulated UAS operation as part of their business 

model, PSS will be able to train others and lead the way to get standards and rules passed

Currently, aerial videography relies primarily on the use of larger aircraft such as manned 

helicopters. Use of such aircraft is highly risky and pollutant as they run on combustible fuel. Further, 

manned aircraft requires the pilot and camera operators to be inside the aircraft, increasing the risk of 

injury both to the operators and those on the ground. Additionally, the weight and speed of the manned 

aircraft are exponentially greater than those of the relevant UASs. These factors alone will 

significantly diminish the risk of human injury and environmental damage while achieving the same 

goal(s). 

Lastly, due to the size of the UAS and the tightly controlled and limited airspace in which the 

UAS will operate, approval of this application presents no risk to national security. 

V. SECTIONS REQUESTED FOR EXEMPTION 

a. 14 CFR § 21, Subpart H: Airworthiness Certificate

Subpart H, Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR § 91.203 (a)(1). With the size and operating area of 
the UAS referenced hereunder, an exemption from Part 21, Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. Read together, 49 U.S.C. § 

44701 (f) and Section 333 of the Reform Act, authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate upon consideration of public interest, size, weight, speed, 

operational capability and proximity to airports and populated areas of the particular UAS.

In this instance, PSS is seeking an exemption for UASs that 1.) are approximately 2.5 pounds 

and 6.5 pounds, drastically lighter than the 55-pound limit; 2.) do not carry a pilot and/or other

personnel; 3.) do not carry fuel, or other explosives; and 4.) will operate solely in secure, limited, 

defined, pre-approved areas, as set forth in Exhibit A. Further, the FAA will have advance notice of all 

operations and flight plans. With the foregoing in place, operation of the UASs will provide a greater 

degree of safety to the public than conventional manned aircraft carriers with airworthiness certificates 

granted under 14 CFR § 21, Subpart H.

b. 14 CFR § 45.23(b): Marking Requirements

14 CFR § 45.23(b) requires that the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must 

also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less 

than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable. However, given the size of the UASs hereunder, the 

lettering is impossible. The FAA has previously issued exemptions to this regulation to exemption 

numbers 12984 and 12985

c. 14 CFR § 61.315 (b) & (C), 61.101 (e), (a) & (b), 61.113(a) & (b): Pilot Restrictions

Under the above referenced regulations, sport, recreational and private pilots are prohibited 

from acting as the pilot-in-command of an aircraft for commercial purposes. However, in this 

instance, the UAS will not carry the pilot, observers, crew, or any other passenger; thus, the same level 

of safety may be achieved by having a sport, recreational and/or private pilot act as the PIC, rather than 

a commercial pilot. Unlike conventional aircraft, the UAS is remotely controlled with no human 

passengers on board at any time. Operation of the UAS is strictly controlled and managed and all 

flights are pre-planned and pre-approved as set forth in the rules proposed in Exhibit A. The safety 
measures required by the standards set forth in Exhibit A and above in paragraph II, exceed the safety 

provided by having a commercial-licensed pilot in command. 

d. 14 CFR § 91.7(a) and (b): Aircraft Airworthiness

14 CFR § 91.7(a) and (b) requires that no person may operate a civil aircraft unless such 

aircraft is in airworthy condition. As PSS is requesting an exemption from obtaining an airworthiness 

certificate, supra, a determination of airworthiness will not be made for the UAS identified hereunder. 

No FAA regulatory standard exists for determining the airworthiness of the given aircraft. Given the 

size, weight, and safety measures put in place for the UAS, an equivalent level of safety will be 

provided for. This exemption was granted in a similar situation in exemptions 12984 and 12985.

e. 14 CFR § 91.9(b): Civil Aircraft Flight Manual 

This regulation states that:

No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this chapter 

unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the 

manual provided for in § 121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

The size of the UAS makes compliance with this regulation impossible. There is no place to 

carry such a flight manual on the aircraft. In order to maintain the equivalent level of safety, the flight 

manual shall be maintained on the ground at the control point where the PIC will have immediate 

access, if needed. 

f. 14 CFR § 91.109: Flight Instruction

This regulation provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

UASs do not have fully functional dual controls. Rather, flight control is handled through the use of a 

remote control box that communications with the UAS device through radio communication waves. 
The FAA has previously approved a number of exemptions to this regulation for various types of 

aircraft. In this instance an equivalent level of safety will be attained as the UAS carries no passengers 

and is smaller in size and weight in comparison to other aircraft. 

g. 14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 provides that:

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure.

This petition requests an exemption for an unmanned aircraft, which is prohibited from flying 

more than 400 feet above ground level. However, as stated above in section II., the UAS will not be 

flown in heavily populated/congested areas and thus, an equivalent measure of safety shall be 

maintained.

h. 14 CFR § 91.121: Altimeter Settings

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

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

altimeter settling available before departure.” An exemption from this section is needed as the UAS 

employs a GPS coordinate and altitude read out rather than a barometric altimeter reading. However, 

such GPS readout provides an equivalent level of safety and should satisfy the underlying reason for 

this regulation. 

I. 14 CFR § 91.151(a): Fuel Requirements

This provision requires that no person begin a flight under VFR conditions unless the aircraft 

has the requisite amount of fuel, as dictated by the regulation. To meet the reserve limits required 

under this regulation, the flight time would be limited to approximately 10 minutes. An exemption 

from this requirement is requested as the conditions under which the UAS would be operated are very 
limited and controlled. An equivalent level of safety can be achieved by limiting flight to 30% of 

battery power or 25 minutes in length (whichever occurs first). This operating restriction would be 

more than adequate to return the UAS to its pre-planned landing destination from anywhere in its 

operating area.

J. 14 CFR § 91.203: Carrying Certification and Registration

The regulation provides, in relevant part:

Except as provided in§ 91.715, no person may operate a civil aircraft unless it has an 

appropriate and current airworthiness certificate, and such is displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew.

An exception is needed from this provision as the UAS hereunder is less than 10 pounds in 

weight and has no passengers and/or crew. It is not feasible, or necessary to place certification (or any 

other type of) documents within the cabin of the UAS. However, any necessary documents will be kept 

at the ground level within immediate reach of the PIC and/or VI.

K. 14 CFR §§ 91.405, 91.407(a)(1), 91.409 (a)(2), 91.417(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 other shall inspect or maintain the aircraft in compliance with Part 43. Given that all of these 

sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the petitioner. Maintenance will be accomplished by the PIC and the petitioner pursuant to the 

operating manual and Exhibit A hereof. An equivalent level of safety will be achieved as the small 

UASs are less than 10 pounds, will carry a small payload, and have a very limited operating range. If 

any mechanical issues arise, the UAS can land immediately and will be operating from n o higher than 

400 feet from ground level. The PIC and VI will ensure that the UAS is in working order prior to 

taking flight. All maintenance and up keep will be performed and logged. In conclusion, all 

maintenance performed on the UAS will meet the equivalent safety standards generally required under 

the above referenced provisions.
NOW THEREFORE, PSS respectfully requests that the USDOT consider and grant its prayer 

for an exemption to Section 333 of the Reform Act. 
Exhibit A

DJI INSPIRE 1 

Preflight Check:

Check locations and make sure you are not with in 5 miles of an airport.

DO NOT fly aircraft above 330ft or near other aircraft or obstructions

Full pre-flight check is performed on the aircraft. 

I. Checking the Battery

Check the battery for damage and deformities. 

II. Checking the Transformation System

Check the servomotor cables and the lead screws . Listen to the servomotors during the transformation,

After the landing gear rises, check the lead screws and bearings. If any dirt or dust is found, clean and

grease the bearings.

III. Checking the Aircraft

Confirm that all the screws are still adequately tightened. Check the aircraft for breaks or damage. 

Check the carbon tubes of the arms for damage. Check the dampers on the landing gears. Ensure that 

there are no obstacles on or around the GPS module or around the antennas on the landing gear.

Check that the right and left landing gear rest at the

same tilt angle.

IV. Checking the Motors

Check the rotors to confirm that they have not become loose. Detach the propellers and start the 

motors. Carefully examine the edge of the rotor and confirm that the shaft is perfectly centered on the 

motor. 

V. Checking the Propellers

Check the propellers. If there is any bending, breakage or cracking on a propeller, do not use it. Attach 

the propeller to the motor, turn on the aircraft, and place it on the ground. 

VI. Checking the IMU

Open DJI Pilot app to check the condition of the IMU and perform an advanced IMU calibration. 

Place the aircraft on a flat, stable surface. Do not touch the craft during the calibration. Turn on the 

aircraft and listen for any abnormal noise or vibration 

VII. Checking the Control and Video Transmission System

Check the 4 antennas on the landing gear. Check the antennas of the remote controller for

damage

VIII. Checking the Gimbal and Camera

Check the quick-mount connector for the camera. Check the metal contacts on the quick mount

connector board, Confirm that the gimbal is able to properly stabilize.
IX. Checking the Vision Positioning System

Check the lens of the camera. Check for and remove objects that might block the

sensors. Ensure that the Vision Positioning System is securely installed on the aircraft.

Detach the propellers and turn on the aircraft. Hold the aircraft 1-2 meters above a surface with rich

patterns, under good lighting conditions. Change the Flight Mode switch to P Mode on the controller

and check the DJI Pilot app. If the app displays an

altitude value and indicates that P-OPTI mode is active, the Vision Positioning System should function

normally.

Location and flight paths are scouted and notated for all ground crew.

GPS records home location so the drone can return in the event that communication with the remote is 

lost.

During Flight: 

Visual contact with the drone must be maintained at ALL times.

Second operator and additional spotters maintains visual contact of the drone.

Pay close attention to the surroundings (other aircrafts, birds and structures). 

Aircraft is never flown directly over people’s heads. Aircraft must stay below 100M (330 FT) at all 

times. Height reading is available as a visual reading on IOS App.

Safe distance from any obstructions will be maintained at all times. 

Should an emergency occur verbal commands would be given so that all spotters 

and drone pilot can take immediate action. 

If an emergency occurs land aircraft immediately. If drone is unresponsive press and hold the “Return 

to Home” button below the right thumb stick and safely land drone. Do not continue to fly and send 

unit back to manufacturer.

Drone battery life will be monitored via the DJI Pilot app. The drone is programmed so that when the 

battery gets to 30% the drone and app will make audible and visual warnings to land the aircraft. 

Post Flight: 

Check drone for any damage that may have occurred during flight. 

Repair or replace any damaged items before returning drone into service. 

DJI PHANTOM 1

PREFLIGHT CHECK

Make sure batteries are fully charged in both TX and drone

Verify mode P on TX

Power on TX**

Power on Drone**

Enable airplane mode on iOS devise. Connect iOS device to USB port 

Load DJI App

Exit storage mode via app or remote (flip landing mode switch back and forth at least four times)

Power Off drone

Attach camera with media
Inspect and clean visual sensors on bottom of drone

Install props. Match up white dots and no white dots

Make sure props are mounted correctly and firmly

Power on drone**

CALIBRATE COMPASS AT ALL NEW FLIGHT LOCATIONS

Set home location

Point antennas correctly on TX (Both vertical and not crossing)

Hit record via app or remote

Utilize auto take off and landing

The remote and app will notify you when the battery is low. 

Return to home and land

** To turn on devices. One short press followed by a 3 second press **

** Same procedure is used to turn off devices **

ADJUSTING CAMERA

To adjust the camera pan\tilt angle press and hold your finger on the Camera page of the Pilot app for a 

few seconds. A circle will appear, which can then be dragged to adjust the orientation of the camera.

CAMERA SETTINGS

4K 30FPS

Set color to LOG

Set white balance

ISO and Shutter must be set manually

Set gimbal to “follow” mode

For sunny daytime shooting attach ND filter to avoid over exposure

* A 32GB SD card can hold up to 72 minutes of footage.

DO NOT CHARGE BATTERY AND REMOTE AT THE SAME TIME

KEEP MAX ALTITUDE SET TO 100M