Chickasaw Nation Multimedia Exemption Request 

1

January 4, 2016

U.S. Department of Transportation 

Docket Management System Room w12-140 

1200 New Jersey Avenue., SE 

Washington, DC 20590 

RE: Exemption Request under section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Chickasaw Nation Multimedia requests exemption from provisions of the Federal Aviation Regulations. These exemption 

requests are in accordance with Section 333 of the Federal Aviation Administration Modernization and Reform Act of 

2012. Chickasaw Nation Multimedia seeks exemption in order to commercially operate the DJI Phantom 2 and the DJI

Spreading Wings s1000 small-unmanned aircraft (sUA) for videography uses for Chickasaw Nation video productions. 

CHICKASAW NATION MULTIMEDIA EXEMPTIONS REQUESTED:

Part 21 Subpart H Airworthiness Certificate 

14 C.F.R. § 61.113(a) and (b) Private Pilot Privileges 

14 C.F.R. § 61.133(a) Commercial Pilot Privileges 

14 C.F.R. § 91.7(a) and (b) Civil Aircraft Airworthiness 

14 C.F.R. § 91.119 Minimum Safe Altitudes 

14 C.F.R. § 91.121 Altimeter Settings 

14 C.F.R. § 91.151(a) Fuel Requirements for Flight in VFR Conditions 

14 C.F.R. § 91.203(a)(1) and (2) Civil Aircraft Certifications 

14 C.F.R. § 91.405; 407; 409; 417 Maintenance Inspections 

INTRODUCTION AND INTEREST OF PETITIONER:

The Chickasaw Nation is a Federally recognized sovereign tribal government headquartered in Ada, Oklahoma. The legal 

boundaries include 13 counties in south central Oklahoma. Chickasaw Nation Multimedia, a department within the 

Chickasaw Nation, was established in 2002. Chickasaw Multimedia is a full video and multimedia production department 

of the Chickasaw Nation tribal government. Chickasaw Nation Multimedia is not a for profit department for public hire. 

Chickasaw Nation is a service-based department created to meet the video production needs of the Chickasaw Nation. 

However, Chickasaw Nation Multimedia develops relationships across local communities, states, and at the Federal 

government level and provides non-compensated assistance where applicable in media and video productions. 
 

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Chickasaw Nation Multimedia covers the history of the Chickasaw people, places, and culture both in Oklahoma and 

abroad for tribal government use in the boundaries of the United States. This coverage includes footage and interviews in 

Oklahoma and the original homelands of the Chickasaw people, which covered parts of modern day Mississippi, 

Alabama, Tennessee, and Georgia. 

Chickasaw Nation Multimedia video productions enhance a cultural understanding and provide educational tools through 

video content to Chickasaw citizens and to the general public. If granted exemption, Chickasaw Nation Multimedia aerial 

videography will not be a for hire profit service for individuals or groups. However, products containing possible future 

aerial videography in documentary series work or feature film productions by the Chickasaw Nation may be made 

available for purchase to the general public. 

When working with the community at large, Chickasaw Nation Multimedia has the opportunity to promote the safe use of 

the small-unmanned aircraft. As part of community relationships, Chickasaw Nation Multimedia takes part in offering 

educational tours, presentations, and lectures to student media groups both in vocational technology centers, public school 

systems, and collegiate systems regarding media production. Alongside presenting cultural and historical information 

through video, Chickasaw Nation Multimedia works with the above-mentioned groups to inspire an interest in video 

production as a career path to high school students in public school systems. 

This exemption will permit Chickasaw Nation Multimedia to operate two unmanned aircraft systems (DJI Phantom 2 and 

the DJI Spreading Wings s1000) for the purpose of conducting aerial videography and photography in these areas. 

• Chickasaw Nation tribal construction sites

• Chickasaw Nation tribal business and commerce sites 

• Footage for CNTV, a bi-weekly non-profit online news program produced about the Chickasaw people, places, 

events, and information. These stories and packages are often shared for free with local news media outlets. 

• General landscapes within the Chickasaw Nation boundaries in Oklahoma as well as sites within the original 

Chickasaw homelands listed above including historic mound sites, rivers, fields, and areas once occupied by the 

Chickasaw people. 

• In addition, some footage gathered via small-unmanned aircraft will be used in feature films and documentaries 

produced entirely by the Chickasaw Nation that showcases Chickasaw people, history, and culture. These 

documentaries and feature films serve a purpose to share Chickasaw history and culture with the world in aims to 

educate and introduce the general public to Chickasaw specific Native American history and government. 

Video productions by the Chickasaw Nation are used to educate both Chickasaw citizens and the general public. 

Chickasaw citizens are enrolled and federally recognized members of the Chickasaw Nation. This is also in addition to 

their United States citizenship. Chickasaw citizens live and reside in various states through out the United States. 

These video productions are used through museum presentations such as the National Museum of the American Indian in 

Washington D.C., colleges and public school systems, and for historical archiving and recording of Chickasaw history, 

culture, and heritage. The Chickasaw Nation has a strong presence through out United States. The Chickasaw have 

existed as a strong ally with the United States Government dating back to alliances and partnerships with our countries 

first president, George Washington. 
 

Chickasaw Nation Multimedia Exemption Request 

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BACKGROUND INFORMATION

1. Unmanned Aircraft Systems: DJI Phantom 2 UAS 

2. Unmanned Aircraft Systems: DJI Spreading Wings s1000 UAS 

Chickasaw Nation Multimedia staff members Brian Harrison and Brad Clonch have flown quad rotorcraft RC copters 

recreationally for 5 plus years without incident. Their experience with RC copters also includes building frames, copter 

maintenance, navigation programming, and monitoring of rotorcraft systems. 

Chickasaw Nation Multimedia seeks an exemption to operate the DJI Phantom 2 and the DJI Spreading Wings s1000 

UAS for use within the National Airspace System.

The DJI Phantom 2 is a vertical takeoff and landing unmanned aircraft with a remote ground operator via remote control. 

The DJI Phantom 2 has a maximum gross weight of approximately 2.8 lbs. It has a diagonal length of 23’’, a maximum 

speed of 33 mph (15 meters/second), and possesses a maximum geo-fenced flight altitude of 200 feet set by end user pilot 

in command. The DJI Phantom 2 is equipped with four main rotors utilizing four electric engines powered by Lithium 

Polymer smart batteries. 

The DJI Spreading Wings s1000 is a vertical takeoff and landing unmanned aircraft with a remote ground operator via 

remote control. The DJI Spreading Wings s1000 has a maximum gross weight of approximately 24 lbs. It has a diagonal 

length of 41’’, a maximum speed with end user programming limit of no more than 15 meters/second (33 mph), and 

possesses a maximum geo-fenced flight altitude of 200 feet set by end user pilot in command. The DJI Spreading Wings 

s1000 is equipped with 8 main rotors utilizing 8 electric engines powered by Lithium Polymer batteries. 

The DJI Phantom 2 and the DJI Spreading Wings s1000 will be operated by Chickasaw Nation Multimedia and will be 

registered in accordance with the FAA. 

The DJI Phantom 2 and DJI s1000 Pilot in Command will hold at minimum a sport pilot license or private pilot licenses 

certificate. Pilot in Command will have completed training on the aerial platforms for programming, flight operations, and 

safety procedures. This training is made available through Troy Built Models, which is located in Sarasota Florida, and is 

a COA and Section 333 exempt facility through the FAA to provide training. 

• Troy Built Models Exemption No. 11493 Regulatory Docket No. FAA-2015-0315

• Troy Built Models COA Certificate FAA-2015-0315-333E

This exemption is in accordance with protocols outlined in this petition for exemption utilizing outlined procedures from 

the following: 

• Training with Troy Built Models on the build, programming and flight small-unmanned aircraft. 

• Following established protocols through DJI Manufacturer and Instructions Manuals for both the DJI Phantom 2 

and the DJI Spreading Wings s1000

• Any other requirement established and mandated by the FAA in accordance to Section 333 of the Reform Act. 
 

Chickasaw Nation Multimedia Exemption Request 

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If granted, this exemption will permit Chickasaw Nation Multimedia to safely operate the mentioned small-unmanned 

aircraft under controlled, cleared, and safe conditions for the purpose of aerial videography. Approval of this exemption 

will extend and enhance the overall safety and fulfill the Secretary of Transportation’s (the FAA Administrators) 

responsibilities to, “...establish requirements for the safe operation of such aircraft systems in the national airspace 

system” consistent with Section 333( c ) of the Reform Act. 

The name and address of the petitioner is: 

Chickasaw Nation Multimedia 

Attn: Brad Clonch, Senior Producer Chickasaw Nation Multimedia 

Phone: 580-332-1416

Email: brad.clonch@chickasaw.net

Address: 121 West Main Street, Ada, OK 74820 

Website: www.chickasaw.net

Fax: 580-332-1159

DESCRIPTION OF FLIGHT OPERATIONS: 

To preserve the safety of manned aircraft operations, the National Air Space, and property, Chickasaw Nation Multimedia 

proposes to maintain the following limitations and conditions during all aerial videography operations if granted 

exemption: 

1. The DJI Phantom 2 and the DJI Spreading Wings s1000 will not exceed any weight restrictions for each platform 

as specified by manufacturer and within the limits of weighing under 55lbs as a registered small-unmanned 

aircraft (sUA). 

2. All flights will maintain direct visual line of sight of the pilot in command and trained visual observer. The pilot 

in command will hold at minimum a sport pilots certificate and/or private pilot certificate/licensing. The visual 

observer and pilot in command will be able to communicate verbally at all times during operation. 

3. The pilot in command will be designated before the flight and will not transfer his or her designation for the 

duration of the flight. Flights will be logged in a flight logbook per each operation. The pilot in command will 

ensure that the visual observer understands each small-unmanned aircrafts functions and characteristics. The 

visual observer will also possess knowledge of both the DJI Phantom 2 and DJI Spreading Wings s1000 

manufacturer operational manual. 

4. Visual observers will receive no less than one hour of instruction on their required duties to maintain obstacle and 

collision avoidance for all flight operations. 

5. Geo-Fencing will be utilized to keep all flight operations at or below specified altitudes of 200 feet and a distance 

not to exceed visual line of sight or a maximum of 1000 feet from the pilot in command at all times. Real time 

telemetry will be monitored at all times to ensure compliance. 
 

Chickasaw Nation Multimedia Exemption Request 

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6. Geo-Fencing will be set and tested as a standard practice prior to any flight operation. 

7. Fail Safe modes will be enabled and tested at the beginning of each flight as a standard return to launch protocol. 

8. If the small-unmanned aircraft loses communication signal at any time, the small-unmanned aircraft will have the 

capability to return to a pre-determined location within a safe, clear, pre-established flight zone and land. 

9. The pilot in command will abort the flight operation in the event of unpredicted obstacles or emergencies. 

10. Flight operations will be conducted in visual flight rule conditions. Operations will be conducted at least 2,000 

feet from fog conditions. 

11. Prior to flight operation, the pilot in command will obtain an official weather briefing for the area of operation no 

more than one hour prior to the planned flight operations. 

12. Chickasaw Nation Multimedia will assure that no individual’s privacy is violated when acquiring aerial 

videography. As a standard practice, Chickasaw Nation Multimedia will always notify any necessary entities in 

flight operations in accordance with operation regulations.

13. No flight operations will be conducted at night. 

14. Small-unmanned aircraft will maintain a safe lateral distance as prescribed by or recommended by the FAA from 

inhabited structures, buildings, vehicles, and remain in constant visual line of sight. 

15. Small-unmanned aircraft will maintain a safe lateral distance from non-participants to maintain a safe flight zone 

as prescribed or recommended by the FAA. If any non-participant enters the safe flight zone, flight operations 

will cease until the flight is cleared. 

16. Signs and notifications displaying “Small-Unmanned Aircraft Flight Operation In Progress” will be positioned to 

keep all persons and objects clear of the safe flight vertical takeoff and landing zone. 

17. All operations shall be conducted over Chickasaw Nation property and/or private or controlled-access property 

with permissions from the land owner/controller or authorized representative. Permission from the land 

owner/controller or authorized representative will be obtained prior to each flight being conducted. 

18. The DJI Phantom 2 and DJI Spreading Wings s1000 will remain clear and yield the right of way to all other 

manned operations and activities at all times including but not limited to: ultra light vehicles, parachute activities, 

parasailing activities, hang gliders, etc. 

19. Prior to flight operations, the pilot in command must inspect the small-unmanned aircraft in use to ensure it is in a 

condition for safe flight. This checklist includes rotor condition, propeller condition, battery condition and charge 

level, as well as structural integrity of components on board. If the inspection reveals a condition that affects the 

safe operation of the small-unmanned aircraft, the small-unmanned aircraft is prohibited from operating until the 

necessary maintenance has been performed and the small-unmanned aircraft is found to be in a condition safe for 

flight. 

20. Any maintenance or alteration that occurs with the small-unmanned aircraft platform on the DJI Phantom 2 or the 

DJI Spreading Wings s1000 will be logged in the official flight logbook as well as tested for a functional flight. 
 

Chickasaw Nation Multimedia Exemption Request 

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21. The operator will carry out its maintenance, inspection, and record keeping requirements in accordance with 

manufacture operating documents. All maintenance, inspections, and/or alterations will be noted in the official 

aircraft logbook. Logbook will include flight hours, description of maintenance, and signature of the pilot in 

command servicing the DJI Phantom 2 or DJI s1000. 

22. The UAS operating under exemption must comply with all manufacturer System and Safety Bulletins. 

23. Operations and control on the small-unmanned aircraft will be conducted with a Federal Communications 

Commission compliant frequency of 2.4gHz band. An FCC license is not required to utilize these frequencies. 

24. All operations will be conducted in Class G airspace. 

25. During Class G airspace operation, the DJI Phantom 2 or DJI Spreading Wings s1000 will not operate within 5 

nautical miles of the geographic center of an airport as listed on the most current FAA published aeronautical 

chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in 

accordance with a Notice to Airmen.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational 

area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 

hours. Accidents meeting the requirements of the 49 C.F.R. Part 830 must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB website: www.ntsb.gov

27. If granted a Section 333 exempt status, a COA will be filled for Motion Picture Filming. Chickasaw Nation 

Multimedia will acquire proper liability insurance for its small-unmanned aircraft drones. 
 

Chickasaw Nation Multimedia Exemption Request 

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BASIS FOR PETITION:

Chickasaw Nation Multimedia will register the DJI Phantom 2 and the DJI Spreading Wings s1000 in accordance with 

FAA requirements through form AC Form 8050-1 and display the registration number (N) on each UAS. Listed below 

are requirements and listed request for exemptions for Chickasaw Nation Multimedia. 

Part 21 Subpart H

Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness certificates. Chickasaw Nation 

Multimedia request an exemption from this subpart to operate the DJI Phantom 2 and DJI Spreading Wings s1000 without 

the requirement for an airworthiness certificate. Based on the proposed small-unmanned aircraft being limited in size, 

weight, speed, operating capabilities, and operating within visual line of sight, Chickasaw Nation Multimedia request 

exemption based on both the DJI Phantom 2 and DJI Spreading Wings s1000 meeting the conditions of FMRA Section 

333. Therefore, an airworthiness certificate is not necessary or required to ensure an equivalent level of safety to manned 

aircraft operations. 

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: PIC (Pilot in Command) 

14 C.F.R. 61.113 (a) and (b) state that: 

• (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person for compensation or hire, act as pilot in command of an aircraft. 

• (b) A private pilot may, for compensation or hire, act as pilot in command 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. 

Chickasaw Nation Multimedia request exemption from 14 C.F.R. § 61.113 (a) and (b) to allow Chickasaw Nation 

Multimedia to commercially operate the DJI Phantom 2 and DJI s1000 UAS’s with operators holding at minimum a sport 

or private pilot certificates/license. Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. However 

provided in recent documentation, it has been determined that the private pilot and commercial pilot certifications meet 

the same basic knowledge of airspace through ground school and not flight training which can be found under the 

following docket: 

* Regulatory Docket No. FAA-2014-0352 page 16-17

A commercial pilots certification ensures that a pilot is able to safely commercially operate a manned aircraft, not a smallunmanned aircraft. Applying manned commercial pilot certification requirements do not significantly add to the safety of 

small-unmanned aircraft operations. Chickasaw Nation Multimedia’s operating procedures will ensure small-unmanned 

aircraft pilots are trained to conduct small-unmanned aircraft operations with an equivalent level of safety to the training 

advantages obtained by a certified commercial pilot for manned aircraft procedures. All Chickasaw Nation Multimedia 
 

Chickasaw Nation Multimedia Exemption Request 

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small-unmanned aircraft pilots will be trained and certified on the platforms they are flying through an FAA exempt (333) 

COA organizations; Troy Built Models (TBM). 

14 C.F.R. § 61.133(a): Commercial Pilot Privileges and Limitations 

Chickasaw Nation Multimedia request exemption from 14 C.F.R § 61.133 (a) in accordance with the above request 

enabling an operator with a sport or private pilot certificate to operate the DJI Phantom 2 small-unmanned aircraft and/or 

the DJI s1000 small-unmanned aircraft commercially. Based on small-unmanned aircraft simplicity and visual line of 

sight operations this exemption would not negate or degrade the safety of the national air space or manned aircraft 

operations. 

14 C.F.R. § 91.7 (a) and (b): Civil Aircraft Airworthiness 

The regulation states that no person may operate a civil aircraft unless it is in an airworthy condition. There is no current 

airworthiness certificate issued for the type of aircraft that the exemption is being proposed. Should Chickasaw Nation 

Multimedia be granted an exemption, no FAA regulatory standard will exist to date for determining airworthiness. Given 

the size of the DJI Phantom 2 and DJI s1000 and the description of proposed operation protocol listed above, an 

equivalent level of safety will be provided. 

14 C.F.R. § 91.103: Preflight Action 

Chickasaw Nation Multimedia requests an exemption from the preflight actions requirements of 14 C.F.R. 91.113 that 

prescribes the preflight actions under which aircraft may operate: Each pilot in command shall, before beginning a flight, 

become familiar with all available information concerning that flight. 

• (a) Flight under instrument flight rules or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known 

traffic delays of which the pilot is in command has been advised by air traffic control; 

• (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance 

information: 

o (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff 

and landing distance data is required, the takeoff and landing distance data contained therein; and 

o (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

All Chickasaw Nation Multimedia flights will be conducted in visual flight rule conditions. No takeoff or landing 

distances are published or detailed for the DJI Phantom 2 or DJI s1000 by the manufacturer. An equivalent level of safety 

will be provided by the pilot in command through obtaining all pertinent weather information from an official FAA 

weather source. 
 

Chickasaw Nation Multimedia Exemption Request 

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14 C.F.R. § 91.119: Minimum safe altitudes 

Chickasaw Nation Multimedia requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 91.119 

that prescribes the minimum safe altitudes under which aircraft may operate: 

• 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 

• Over other than congested areas at 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. 

Section 91.119(d) allows helicopters to operate at less than those minimum altitudes when it can be operated without 

hazard to persons or property on the surface given that each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA. 

To provide the intended operations, the DJI Phantom 2 and DJI Spreading Wings s1000 will be operated below 200 feet 

above ground level. Additional safe measurements will include that the small-unmanned aircraft maintain a lateral 

distance of at least 500 feet from inhabited structures, buildings, vehicles, and remain in constant visual line of sight. 

14 C.F.R. § 91.121: Altimeter Settings 

This regulation requires each pilot in command operating an aircraft maintain the cruising altitude or flight level of the 

aircraft by reference to the current reported altimeter setting of a station along the route and within 100 nautical miles of

the aircraft. 

Chickasaw Nation Multimedia seeks an exemption because the DJI Phantom 2 and the DJI Spreading Wings s1000 do not 

have barometric altimeters, but they do possess a GPS altitude reading. Geo Fencing programming will be included on the 

DJI Phantom 2 and the DJI Spreading Wings s1000 for each small-unmanned aircraft to remain at or below 200 feet 

above ground level, further ensuring operation at a safe altitude within visual line of sight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Chickasaw Nation Multimedia requests an exemption from 14 CFR 91.151(a) fuel requirements for flight in visual flight 

rules conditions. Section 91.151 states: 

• (a) No person may begin a flight in an airplane under visual flight rules conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and 

assuming normal cruising speed

The batteries powering the DJI Phantom 2 provide approximately 15-18 minutes of maximum flight time. The batteries 

powering the DJI Spreading Wings s1000 provide approximately 18-20 minutes of maximum flight time. Flight 

operations will be monitored safely and respond to a minimum voltage detector onboard each aircraft. This measurement 

and detector ensures appropriate reserve battery to maintain an equivalent of safety at all times. If the pilot in command

fails to land the small-unmanned aircraft prior to the allotted minimum voltage, the small-unmanned aircraft will enter a 

safety procedure to autonomously return to its original launch position on both the DJI Phantom 2 and the DJI Spreading 

Wings s1000. 
 

Chickasaw Nation Multimedia Exemption Request 

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14 C.F.R. § 91.203(a)(1) and (2): Civil aircraft: Certifications Required

Under this proposal Chickasaw Nation Multimedia would not be operating the small-unmanned aircraft with an 

airworthiness certificate as requested under the exemption for Part 21 subpart H. The exemption for this section is 

required as Chickasaw Nation Multimedia would not be able to display the airworthiness certificate in accordance with 14 

C.F.R. 91.203 (a) (1) and (2). 

14 C.F.R. § 91.405; 91.407; 91.409; 91.417: Maintenance/Operations/Inspections/Records

These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) states 

each owner or operator of an aircraft shall have the aircraft inspected as prescribed in subpart E of this part and shall be 

between required inspections. In addition have discrepancies repaired as prescribed in part 43 of this chapter. 

Chickasaw Nation Multimedia request an exemption as these sections require that the aircraft be inspected in accordance 

with part 43. These sections apply only to aircraft with an airworthiness certificate. An equivalent level of safety will be 

achieved by the pilot in command following the above listed protocol operations manual as well as DJI users manuals for 

each small-unmanned aircraft. The pilot in command will ensure that the small-unmanned aircraft in operation is in 

working order prior to each flight. The pilot in command will maintain a detailed log of maintenance performed. The 

pilot in command is the person most familiar with the aircraft and the one who will provide the equivalent level of safety. 

Flight logs will exist with all maintenance records, flight logs, and other necessary information to ensure proper working 

order. 

PUBLIC INTEREST AND BENEFIT:

The registration of Chickasaw Nation Multimedia’s small-unmanned aircraft and the Section 333 exemption request will 

help support integration and add to maintaining the safety to manned aircraft operations in the National Airspace System. 

Through registration, training, and following established protocols from the FAA, Chickasaw Nation Multimedia will 

have the ability to operate and not pose a threat to the safety or well being of individuals, property on the ground, or other 

aircraft in the air. Chickasaw Nation Multimedia’s aerial videography helps preserve the history, culture, and stories of the 

Chickasaw people. These stories and information add to public information and knowledge through American history. 

Further more, academics and researchers of Native American history and culture will find aerial videography provides a 

new view and perspective of historic sites and locations for observation. The educational aspect given through sharing 

productions with public schools, universities, museums, and other avenues generates better cultural awareness among 

Native American people still living and thriving in the United States. 

Further public benefit includes a positive introduction and uses of unmanned aerial systems (UAS) technology. Through 

registration and exemption in a safe and legal manner, entities such as Chickasaw Nation Multimedia will help create a 

positive public view and understanding of unmanned aerial systems. Chickasaw Nation Multimedia extends and shares its 

expertise in media production to assist local public schools, vocational technology centers, local city government, federal 

government agencies such as the BIA (Bureau of Indian Affairs), and other media groups including other Native 

American media groups. Having the exemption and legal certification can help develop a positive public view on “drone” 

use. 
 

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Because of the size and power source of the DJI Phantom 2 and DJI Spreading Wings s1000, the public will benefit from 

low to zero noise pollution. This noise pollution and decibel level is compared to traditional helicopter or airplane craft

conducting the same aerial videography. The National Airspace System would not be further strained with manned 

aircraft operation for videography purposes. Utilizing small-unmanned aircraft is ecologically friendly due to non-existent 

combustible fuel sources based off small-unmanned aircraft rechargeable battery technology. The use of batteries reduces 

the carbon footprint of a traditional combustion engine and the amount of fuel needed to complete a similar style shot. 

Other benefits include less stress on airport congestion, as both the DJI Phantom 2 and DJI Spreading Wings s1000 do not 

require runway space. 

By utilizing small-unmanned aircraft such as the DJI Phantom 2 and the DJI Spreading Wings s1000 to perform aerial 

videography acquisition, the substantial risk to life and property in the air and on the ground is substantially reduced. This 

is in comparison with traditional aircraft utilized such as a helicopter or an airplane. Furthermore, the weight of the DJI 

Phantom 2 weighing in at 2.8 lbs. and the weight of the DJI Spreading Wings s1000 weighing in at 24 lbs. has less 

physical potential for collateral damage to life and property on the ground, and in the air, compared to traditional aircraft 

performing the same operation. (Approximate comparisons of a plane averaging 6,000 lbs., wingspan of 42 feet, length of 

34 feet, and fuel capacity of 180 gallons)

CONCLUSION:

This petition is made pursuant to the FAA Modernization and Reform Act of 2012 section 333, which directs the 

Secretary of Transportation to determine if certain small-unmanned aircraft may operate safely in the National Airspace 

System. As such, Chickasaw Nation Multimedia’s request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.F.R. Part 11. FMRA Section 333 sets forth the requirements for considering whether smallunmanned aircraft will create a hazard to users of the National Airspace System or the public, or otherwise poses a threat 

to national security; and further, provides the authority for such small-unmanned aircraft to operate without airworthiness 

certification. 

As mentioned in detail above, Chickasaw Nation Multimedia will operate the DJI Phantom 2 and the DJI Spreading 

Wings s1000 safely in the National Airspace System, without creating a hazard to users of the National Airspace System, 

or the public, or otherwise pose a threat to national security. 

Chickasaw Nation Multimedia is seeking Section 333 exemption of the 2012 FMRA to permit safe operations of the DJI 

Phantom 2 and the DJI Spreading Wings s1000 UAS(s) commercially, without an airworthiness certificate, for the limited 

purpose of conduction aerial video and photography over certain areas of the United States. By granting this petition, the 

FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012 

(FMRA) and advancing public interest, by allowing Chickasaw Nation Multimedia to safely, efficiently, and 

economically operate the DJI Phantom 2 and DJI Spreading Wings s1000 commercially within the National Airspace 

System. 

Brad Clonch

Senior Producer-Chickasaw Nation Multimedia

121 West Main Street

Ada, Oklahoma 74820 

www.chickasaw.net
 

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APPENDICES 

• Digital link to DJI Phantom 2 Manual 

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

• Digital link to DJI Spreading Wings s1000 Manual 

http://dl.djicdn.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

• Attached DJI Spreading Wings s1000 Flight Check List 

• Attached Example Flight Log for DJI Phantom 2 and DJI Spreading Wings s1000

• Attached Completed Training Certificates for Build, Programming, Flight from Troy Built Models (a FAA 

COA/333 Exempt training facility, Sarasota Florida) 
 

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o DJI 5-1000 PREFLIGHT CHECKLIST

o Check area to fly on Google maps

o Confirm walkie talkie and ATC coms operation

o Inform ATC of your flight plan if required

o Determine emergency flight plan and alternate landing zones avoiding power lines and obstacles

o Check wind direction

o Set a perimeter of 50-100 meters - area must be clear of people

o All antennas (9?) installed and all pointing in correct directions

o Engage GCS, monitor, laptop, goggles, etc. (bring up flight plan)

o Remove lens cap / Clean lens

o Camera On

o Ensure camera has SD card installed.

o Check battery voltage

o Install battery on copter.

o Check CC

o Level copter with front pointing in correct direction for course lock - do not turn on

o On Copter TX - Set switches - Throttle Down, Return to Home switch Off, Manual Flight Mode

Switch On, Flight Path Switch Off - Not Course or Home Lock

o Copter Transmitter On

o Check Model Selection on Tx

o Check Tx battery voltage (above 7.4v)

o On Photo Tx - set switches - HDMI switch Ofl Freestyle switch On

o Photography Transmitter On

o Check Model Selection on Tx

o Check Tx battery voltage (above 7.4v)

o Plug in battery black lead first.

o Calibrate GPS/Compass if necessary

o lfcalibrated, cycle battery with correct heading for course lock.

o Do not touch the Copter until 30 seconds after full GPS Lock. Initial 3 red blinks is normal meaning

no GPS lock. Wait until no flashes. Continue with checklist.

o Check Copter Voltage frorn GCS

o Engage Attitude Mode - Must Achieve Double Amber Flash

o Engage GPS Mode - Must Achieve Double Purple Flash

o While in GPS mode engage "Course Lock" mode. Must achieve green Flash

o Do not engage motors. Set throttle to center position. Must achieve single amber flash in Attitude

Mode and single purple flash in GPS mode

o HDMI switch On (video on camera itself should go off)

o Freestyle switch On (FPV Ofl)

o Verifr camera operation (If problems, check Drive Mode - Remote Cmdr must be "on", manual focus,

intelligent auto)

o Verify data link if installed - rolling copter manually should change gauges

o Upload flight plan

o Verify altitude is about 0 via gauge on computer/GCS/video monitor/goggles

o Timers set properly

4 Ia 2014Troy Built Models, lnc. Alt Rights Reserved.
 

Chickasaw Nation Multimedia Exemption Request 

14

TAKEOFF CHECKLIST

o Declare intentions for takeoff with ATC

o Engage GPS mode - Double purple flash

o Engage Course Lock mode (double green flash) o Announce loudly: "CLEAR pROp,,

o Position the sticks in the lower left hand corners, then immediately raise the throttle 2 clicks, and center the right stick.

o Advance throttle to /+ power for 5 seconds. Assure all motors are operating. o Verifl' thatleftlright and forward/back stick movement engages the propeimotors o Verif,z data and video links are still operational

o Announce loudly: "TAKING OFF,,

o Advance throttle to full. copter must jump off of the ground.

o Ascend to 3 meters. Center throttle stick. Should be single green flash. Verif, wireless link, GPS hold, camera operation, gauges, etc. are working pioperly. o Verift course lock is operational by rotating 90 degrees and pushing forward on stick. o VeriS' copter stability. If unstable, Iand and reset gains, recaiibrate, or retest as necessary. o Raise landing gear

o Proceed with manual mission

o For autopilot operation

. Ascend to 10 meters manually

. Engage autopilot

o Manual pilot/observer must monitor the informational LED and be ready to take over in

manual mode when necessary.

o Manual pilot to request copter flight battery voltage readout from camera operator

periodically.

QUICK PREFLIGHT CHECKLIST

o Landing zone clear

o Level copter with correct heading

o Battery 4.1+ 111, 3.8 depleted

o Camera on. SD card in.

o Both TX - all switches down

o Both TX on

o Copter on

o Check GPS and Course lock checks

o Video check

o Photo check

o Timers ready

o Takeoff

o Raise Landing Gear

o Unplug 6 batteries upon landing

@ 2014 Troy Built Models, Rights Reserved
 

Chickasaw Nation Multimedia Exemption Request 

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