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March 17, 2015 Chosen Productions

Attn: Greg Steinmetz

4316 McCahill Rd

Red Bank, TN 37415

352-266-7180

greg@chosenproductions.org 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 11, 

and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C. 

§ 44701(f),Chosen Productions (“Petitioner”) hereby petitions for exemptions from:

14 C.F.R. Part 21 Subpart H

14 CFR § 45.23

14 CFR § 45.29

14 CFR § 91.203(a) & (b)

14 CFR § 91.9(b)(2)

14 CFR § 61.113 (a) and (b)

14 CFR § 91.119

14 CFR § 91.121 

14 CFR § 91.151 

14 CFR Subpart E § 91.403

14 CFR Subpart E § 91.405(a)

14 CFR Subpart E § 91.407

14 CFR Subpart E § 91.409

14 CFR Subpart E § 91.417

8900.227 Paragraph 16(e)(1)
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Petition Summary

The proposed exemptions, if granted, would allow Petitioner to operate unmanned aircraft 

systems (“UAS”) weighing 55 pounds or less for the purpose of aerial still photography, aerial 

videography and closed-set filming of motion pictures. Based on the small size of Petitioner’s 

UAS, the qualifications and experience of Petitioner’s UAS operators, and the restricted, sterile 

environment within which Petitioner will operate, the requested exemptions fall squarely 

within the zone of safety envisioned by Congress set forth in Section 333. The Petitioners, in the 

past have chartered full-sized helicopters for the purpose of video production, which has 

proven more costly and with a higher safety risk than that of a small UAS. Chosen Productions 

highest goal is the safety of the public, property and national airspace. The UAS will be 

operated in accordance with the FAA policy N 8900.227 Section 14 “Operational Requirements 

for UAS”. The specific guidelines and procedures detailed in the “Operations Manual” and the 

“Pilots Operating Handbook” proposed by the Petitioner gives the FAA good cause to find that 

the UAS operations are in the public interest. 

EXEMPTION REQUESTS AND EQUIVELANT LEVEL OF SAFETY

14 CFR Part 21, Subpart H: Airworthiness Certificates 

Petitioner requests an exemption of 14 CFR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the following

paragraph and attached operations manual. If an airworthiness certificate exemption is not 

appropriate for this application, then petitioner requests an experimental certificate be issued 

under either or both of the following provisions:

21.191 Experimental Certificates

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes, we would expect that 

an experimental certificate, if applicable, would permit our commercial purpose as well. The 

aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements outlined in Petitioners Operations Manual. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 
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"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

Petitioner proposes to achieve an equivalent level of safety, if an experimental certificate is 

required, by including the word "EXPERIMENTAL" on a placard on the rear of the aircraft where 

the PIC, VO and others in the vicinity of the will be able to see the designation. An additional

placard, described in the following section, displayed on the aircrafts ground station will 

provide the aircraft's registration information at the ground level also. 

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 27 pounds, the UAS is too small to carry the required “legible” 

documentation, is not capable of carrying passengers or crew, and does not have an entrance. 

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 placard outlined in the 14 CFR 45.23 exemption 

section above, be permanently affixed to the aircraft via placard containing the word 

“EXPERIMENTAL” (if applicable) to satisfy the requirement of 14 CFR 45.23. Petitioner is also 

prepared to “fold” documentation into a smaller form factor to be displayed in the aircraft if 

needed.

14 CFR 91.9(b)(2), 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. Petitioner assumes 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.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

approved UAS Flight Manual must be available to the crew at the ground station anytime the 

aircraft is in, or preparing for, flight. 

14 CFR 61.113 (a) and (b) 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 of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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 
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passengers or property for compensation or hire. Our proposed operations require that the PIC 

must either:

1. Hold a Private Pilots Certificate issued by the FAA

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" 

in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the 

FAA Private Pilot written examination."

There are currently no means available for the pilot of a UAS to gain the experience in an 

equivalent category and class in order to apply for a commercial pilot's license, we propose to 

generate an equivalent level of safety. Petitioner’s PIC currently holds a Private Pilots 

Certificate issued by the FAA. 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 91.119 Minimum safe altitudes: General

14 CFR 91.119(c) states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, we cannot comply with this requirement. 

Consistent with the relief typically provided to manned operations under FAA Order 8900.1, Volume 

3, Chapter 8, Section 1, Petitioner requests relief from 14 CFR 91.119 in respect to those 

participating persons, vehicles, and structures directly involved with the filming process. Petitioner’s 

Operating Manual sets forth safety factors for authorizing and consenting production personnel. 

Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft.

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an barometric 

altimeter setting available within 100 NM of the aircraft. 

The UAS 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, in feet, 

above the takeoff point is transmitted via radio from the UA on-board computer to the display 

screen held by the PIC, providing a constantly updated AGL readout. Petitioner seeks such relief 

because Petitioner will not have a typical barometric altimeter onboard the UAS. Instead, 

altitude information is generated by GPS equipment installed onboard the UAS and digitally 

transmitted to the ground station display. Prior to each flight, a zero altitude initiation point 

will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for 

granting the requested relief from 14 C.F.R. § 91.121.

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
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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.

Petitioner seeks exemption regarding; the UAS is battery operated and the maximum duration 

of flight with payload from a single battery charge is 9 minutes 30 seconds minutes with a 30% 

reserve. Since the aircraft will never fly more than 3/4NM from the point of intended landing, a 

full battery charge at launch (procedures outlined in the Pilots Operating Handbook) will ensure 

that we meet the reserve energy requirement of this paragraph. 

14 CFR Subpart E (91.403, 91.405(a), 91.407, 91.409, 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 VO perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." Petitioners VO has six years’ 

experience in maintenance and service with this type of aircraft. As provided in the Pre-Flight 

Checklist, both the PIC and VO will ensure that the aircraft is in an airworthy condition prior to 

every flight. This is also how the petitioner will comply with 14 C.F.R. 91.7(a) Civil Aircraft 

Airworthiness. The Pilots Operating Handbook outlines documentation required for the 

maintenance, service and inspecting the UAS. The VO will document work performed in 

accordance with 91.417. We feel that due to the size, construction, and simplicity of the 

aircraft, petitioner can ensure an equivalent level of safety.

8900.227 Paragraph 16(e)(1) Observer Medical

This policy provides that both the PIC and VO must have a valid FAA second-class medical

certificate issued under Part 67 in order to perform as a pilot or observer.

Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC 

and VO become medically incapacitated while the aircraft is in flight, the UAS will return 

autonomously to the site of launching and land without crew intervention. Petitioner currently 

complies with the minimum medical requirements for the PIC as described in Paragraph 

16(c)(4). Petitioner requests exemption from 8900.227 Paragraph 16(e)(1) requiring the VO to 

meet the same medical requirements as commercial pilot carrying passengers in a large aircraft 

Petitioner requests the minimum requirements for VO be vision corrected to 20/20. The 20/20 

vision requirement will ensure that both the PIC and VO can see and avoid air traffic.