CVM Productions

Ron Vander Molen

130 Roy’s Drive

Mishawaka, IN 46544

O: 574-256-0068

C: 574-532-0491

ronv@cvmproductions.com

April 27, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue SE 

Washington, DC 20590

To whom this may concern,

Please accept this letter as CVM Productions’ petition for exemption pursuant to 

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

CVM Productions, operator of small Unmanned Aircraft Systems (sUAS) equipped to 

perform aerial photography and videography, hereby applies for an exemption from 

the listed Federal Aviation Regulations to allow commercial operations of its sUAS 

as long as such operations are conducted within the conditions established and 

outlined by the FAA as required by Section 333.1. The exemption requested would 

allow the operation of unmanned sUAS under conditions in airspace that are limited, 

predetermined and controlled.

Founded in 1991, CVM Productions is a video production company specializing in 

videography and photography for corporate, industrial, automotive and broadcast 

clients. CVM owner and sUAS pilot in command, Ron Vander Molen has been a 

licensed private pilot since 1989 and has been flying radio-controlled model 

aircrafts for over 35 years. He also maintains a current Class III medical certificate. 

CVM Productions plans to utilize the capabilities of the sUAS for a number of 

services including:

 Aerial photography and videography for corporate, industrial and 

automotive clients

 Real estate photography

 Event photography/videography for broadcast clients (ABC, ESPN, FOX)

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe 

civil UAS 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. CVM Productions 

meets all requirements to permit FAA approval of commercial UAS 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. 91.121Page 3

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) 

The purpose of this petition for exemption is to enable CVM Productions to operate 

a DJI Inspire 1 (model #T600) equipped with a two-axis camera gimbal and using a 

High-Def camera. This sUAS has a built-in capability to limit the height it flies above 

the ground, to limit the radius of the distance it flies from the operator. The Inspire 1

also has the failsafe function of the autopilot system, which means when the 

communication between the main controller and the transmitter is disconnected, 

the outputs of all command sticks from controller will go to the center position. If 

the GPS signal is good enough, the system will automatically trigger Return to Home 

and will land safely. The DJI Inspire also has a second controller for camera control. 

The second controler allows for a camera operator to control all camera functions 

while the pilot in command flies the aircraft. Total aircraft weight is approximately 

6.5 lbs. including the battery, gimbal and camera. 

Please refer to the included DJI Inspire 1 Instruction Manual for the performance 

limitations and flight operations. (http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pd

f ) A pre-flight inspection will be performed by the pilot in command in accordance 

with the factory instruction manual. An added step will be the inspection of the 

propellers. A propeller will be replaced if it has any nicks and cracks with a 

manufacturers authorized propeller. 

The sUAS will be maintained in accordance with the manufacturers instruction 

manual and only manufacturer's authorized replacement parts will be used. 
FCC Information 

The C1 transmitter used for controlling the sUAS complies with part 15 of the FCC 

rules. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference, and (2) this device must accept 

any interference received, including interference that may cause undesired 

operation.

The C1 radio transmitter used for controlling the sUAS is wireless technology, which

has been tested and found to be compliant with the applicable regulations governing 

a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

When operating our C1 transmitter, the pilot in command will maintain a separation 

distance of at least 5 cm between his body (excluding fingers, hands, wrists, ankles 

and feet) and the antenna to meet RF exposure safety requirements as determined 

by FCC regulations. 

Pilot in Command and Observer Qualifications and Duties 

The pilot in command will maintain at least a Private Pilot Certificate and a current 

Class III medical certificate, plus at least 2 hours flying time and 3 takeoffs and 

landings within 30 days in the type of UAS utilized in operations. The pilot in 

command will also have at least 100 hours total time and at least 30 hours flying 

Radio Controlled Model Aircraft of which will be 10 hours flying sUASs. 

The pilot in command is responsible for the safe and efficient operation of the 

aircraft. Specific duties include all preflight preparation, in flight operation, post 

flight requirements, all procedures including but not limited to: 

Safe in flight operations

Risk Mitigation to Persons and property Airfield Suitability 

The observer must have the visual acuity to observe the sUAV and be able to 

communicate clearly with the pilot in command. The observer’s duties include: 

Warning the pilot of any impending obstacles in the flight path of the sUAS. Warning 

the pilot of any deviations in the planned flight path of the sUAS. Warning the pilot 

should any unauthorized personnel appear in the area of the planned flight. The 

observer will have the authority to order the pilot to terminate the flight should he 

feel the flight cannot be conducted safely. 

General Operating Standards 

• CVM Productions 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. Such operations will insure that the sUAS will "not create a hazard to users of 

the national airspace system or the public." 
• Before an operation of a sUAV within 5NM of an airport with a control tower, the 

control tower will be called to gain permission to operate the sUAS. The PIC will give 

the position, altitude and the times the sUAV will be operated. The sUAS will not be 

operated at an altitude of over 150 feet AGL. Weather minimums will be 3 miles 

visibility and a 1000-foot ceiling. 

Before an operation of a sUAS within 5NM of a non-tower controlled, airport 

operators will be notified and the pilot in command will give the right of way to 

avoid flying in the proximity of full-scale aircraft. At no time will the sUAV be 

operated within the final approach course and the takeoff course of any runway. The 

sUAV will not be operated at an altitude of over 150 feet AGL. Weather minimums 

will be 3 miles visibility and a 1000-foot ceiling. 

• Maximum flight time for each operational flight will be 20 minutes. 

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

the 20- minute limit. 

• The sUAV 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 sUAV operated by the petitioner weighs less than 55 pounds, including the 

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

• The sUAV will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the sUAV and the restricted sterile environment within 

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

requirements. 

The UAS, 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 20 minutes, this is 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 applicants in the past have chartered 2-

seat full-sized helicopters for this purpose, which has proven more costly than many 
potential clients have been able to afford. The benefits of reduced cost and improved 

quality of presentation from the UA will be valuable to and benefit many buyers and 

sellers of real property. 

Additionally, we request that we be allowed to use our system to benefit first 

responders nearby who might require assistance, including fire fighters, the police, 

the sheriff, et al., while remaining subject to all limitations cited in this application as 

we do so. 

(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) CVM Productions will not be operated over densely populated areas;

(g) CVM Productions will not be operating over any open-air assembly of people; (h) 

CVM Productions will not be operating over heavily trafficked roads;

(i) CVM Productions will not be operating at night. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

CVM Productions requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the sUAV 

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 DJI Inspire 1

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 such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental 

certificate 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. Combined with the UA's light weight, being constructed primarily of 

carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, 

than a conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, then 

we request 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 previous paragraph. 

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 "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. The sUAV 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. We propose to achieve an equivalent level of 

safety by including the word "EXPERIMENTAL" in the placard on the top of the 

aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and 

others in the vicinity of the aircraft while it is preparing for launch will be able to 

see the designation. Additionally, we feel that the permanent placard discussed in 

the previous paragraph will provide the aircraft's registration information at the 

ground station. Finally, we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 

inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 

station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin. 

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 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 passengers or property for 

compensation or hire. Our proposed operations require that the PIC must hold at 

least a Private Pilot Certificate with a Class III Medical 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." 

Training will be conducted at a local Radio Control Club flying field. CVM 

Productions has the ability to provide "dual controls" utilizing two C1 transmitters 

with a wireless link between the transmitters. One transmitter is designated the 

master transmitter and the other transmitter is designated as a slave. The PIC 

instructor, utilizing the master transmitter, will be at all times be able assume 

control of the sUAV. 

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 flight path 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 UAS, 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 dayvFR 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 sUAV 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 3/4 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 5.3 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 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 plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23. 

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 UAS 

CVM Productions will be using the UAS 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 a few. Replacing significantly larger manned 

aircraft carrying crew and flammable fuel with small UAS carrying no passengers or 

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

CVM Productions requested exemptions, the FAA will help drive development of 

safe and successful commercial UAS operations and will advance the public 

knowledge base for such operations. CVM Productions is committed to promoting 

the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA 

by sharing data from its commercial UAS operations and serving as a resource for 

future UAS research operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion 

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

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

the line of sight of the pilot in command, 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. 

Our sSUA has proven capability for controlled flight. It is a device offered for general 

sale on the market around the world and has 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 

CVM Productions should be permitted to conduct small UAS 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. 

Thank you for your consideration.

Ron Vander Molen, CVM Productions