Videophotog Productions (Videophotog.com)

256 Tropic BLVD East

Largo, FL 33770

dan@videophotog.com

727 492 3223 Dan Foard iPhone

cameron@videophotog.com

727 600 5299 Cameron Foard iPhone

Docket Operations, M-30

U.S. Department of Transportation

Room W12-140, West Building Ground Floor 1200 New Jersey Avenue, SE.

Washington, DC 20590-0001 

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 (the “Reform 

Act”) and 14 C.F.R. Part 11, Videophotog Productions (Operator) seeks an 

exemption from Federal Aviation Regulations (FARs) to allow commercial operations of 

their UASs (Unmanned Aerial Systems) for the purpose of conducting aerial 

photography, video, and survey for various industries Broadcast TV & News. 

Regarding the Unmanned Aircraft Systems 

The requested exemption would support 

The “Blanket COA” for commercial operations described on the FAA Website:

The Federal Aviation Administration has established an interim policy to speed up airspace authorizations for 

certain commercial unmanned aircraft (UAS) operators who obtain Section 333 exemptions. The new policy 

helps bridge the gap between the past process, which evaluated every UAS operation individually, and future 

operations after we publish a final version of the proposed small UAS rule.

Under the new policy, the FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to 

any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime 

Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances 

away from airports or heliports:

• 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

• 2 NM from an airport without a published instrument flight procedure or an operational tower; or

• 2 NM from a heliport with a published instrument flight procedure

The “blanket” 200-foot COA allows flights anywhere in the country except restricted airspace and other areas, such as 

major cities, where the FAA prohibits UAS operations. Previously, an operator had to apply for and receive a COA for a 

particular block of airspace, a process that can take 60 days. The agency expects the new policy will allow companies and 

individuals who want to use UAS within these limitations to start flying much more quickly than before.

Section 333 exemption holders will automatically receive a “blanket” 200 foot COA. For new exemption holders, the FAA 

will issue a COA at the time the exemption is approved. Anyone who wants to fly outside the blanket parameters must 

obtain a separate COA specific to the airspace required for that operation. 
Docket Operations April 11, 2015 Page 2 

1. The Inspire 1 is a Quadcopter UAS capable of capturing 4K video and transmitting an HD video 

signal to a ground station. Equipped with retractable landing gear, it can capture an unobstructed 

360 degree view from its camera. The built-in camera has an integrated gimbal to maximize 

stability and weight efficiency while minimizing space. When no GPS signal is available, Vision 

Positioning technology provides hovering precision.

2. Reference Inspire 1 Maintenance Manual v1.0 

3. Reference Inspire 1 User Manual (EN) v1.0 [FCC Compliance – Appendix Pg 62] Regarding the 

Unmanned Aircraft PIC 

4. Operator proposes to operate its UASs with a pilot holding, at a minimum, a private pilot 

certificate. 

・・The UAS PIC will be trained in advance for the safe operation of the UAS to be 

operated. This will include operation of the UAS both in normal and emergency modes of 

operation, and will include familiarization with the user manual published by the UAS 

manufacturer. Training will also include types of maneuvers to be performed and the 

safe operation in relation to persons, property and applicable airspace. 

・The PIC must have accumulated a minimum of 100 flight cycles and 25 hours of total

time as a UAS pilot and at least 10 hours logged as a UAS’s pilot with a similar UAS type. 

 ・・All operations must utilize Visual Observers (VOs). VOs who are not pilots will attend

ground training to understand the roles of an observer, communication procedures, and 

proper visual scan techniques, operations at non-towered airports, and appropriate 

sections of the Aeronautical Information Manual. 

5. The PIC must possess at least a third-class airman medical certificate for all of 

petitioner’s flight operations. 

Regarding the Operation of the Unmanned Aircraft 

6. Operator proposes Civil Commercial operation of an UAS to operate in the following 

manner: 

o ・・Aerial photography and/or video for public and/or private use including real

estate, architecture, land surveying, engineering and other related professional 

activities. 

o ・・Aerial video and/or photography for public and/or private use including

television, public events, cinematography and newsgathering. 

o ・・Aerial inspection/photography of residential/commercial structures under

contract with the owners or local government authority. 
Docket Operations April 11, 2015 Page 3 

 ・・Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

 ・・Aerial video/photography or providing live video feed (so as long as all other

parameters are met contained herein) to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government 

has requested it by contract or donation. 

 ・・The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of a UAS for the 

purpose of the safe operation of a UAS to enhance the safety of the National Airspace 

System (NAS) as well as for the protection of the persons and property. 

・For additional operator adherence:

o Reference–Inspire1SafetyGuidelinesv1.0 

7. The UAS may not be flown at an indicated airspeed exceeding 50 knots The UAS must 

be operated at an altitude of no more than 200 feet above ground level (AGL). The UA 

may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. UAS operations may not 

be conducted during night, as defined in 14 CFR § 1.1. 

 ・・All operations must be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized. 

 ・・A briefing will be performed regarding the planned UAS operations prior to each day’s

flight consisting of all the days’ production activities. 

 ・・Flights will be terminated at 20% battery power.

8. As described fully above, the requested exemption would permit the operation of an UAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined 

and d) will provide safety enhancements to the already safe operations in the industry presently 

using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill 

the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace system.” 
Given the small size of the UAS and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the Docket Operations April 11, 2015 Page 4 level 

of safety surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. 

9. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with the airport’s 

management is obtained, and the operation is conducted in accordance with a Notice to Airmen 

(NOTAM), as required by the operator’s COA. 

10. The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO at all 

times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. 

11. Reference – Inspire 1 Safety Guidelines v1.0

12. Operator’s Point of Contact – Daniel Foard 256 Tropic BLVD E LARGO, FL 33770 Cell: 

727492 3223 Alternate Contact PH Cameron Foard 7274923223

Exemption Requests and Equivalent Level of Safety

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 (a)(1) 

Based on the limited size, weight, operating conditions, design safety features, and the imposed 

conditions and limitations, Operator has demonstrated that its operations would not adversely 

affect safety compared to similar operations conducted with aircraft that have been issued an 

airworthiness certificate under 14 CFR part 21, Subpart H. Therefore, as the FAA found for 

Astraeus Aerial (http://www.astraeusaerial.com), Exemption 11062, the requested relief from 14 

CFR Part 21, and any associated noise certification and testing requirements of part 36, is not 

necessary. 

14 CFR § 45.23 (b) – Display of marks 

Since Operator’s UAS has no entrance to the cabin, cockpit, or pilot station on which the 

markings can be placed, two inch lettering will be impossible. 

Official marking systems for small UAS have not yet been established for operations inside the 

NAS. 
Docket Operations April 11, 2015 Page 5 

Operator is prepared to mark the UAS with the name of the organization and location nor origin 

and fulfill any other request by the FAA to this topic in accordance with 45.29 (f) where the pilot, 

observer, and others working with the sUAS will see the identification of the sUAS. The FAA has 

issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 

10700. 

14 CFR § 61.113 (a) & (b) - Private pilot privileges and limitations 

This regulation provides: 

(a) This regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. 

(b) This 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. 

All the requirements of a private pilot certificate will prepare the UAS operator for the 

environment that they will be operating in. 

*Please reference Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA 

determined that a PIC with a private pilot certificate operating a UAS would not adversely affect 

operations in the NAS or present a hazard to persons or property on the ground. 

14 CFR § 91.7 (a) & (b) - Civil aircraft airworthiness

This regulation provides:

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is 

in condition for safe flight. The pilot in command shall discontinue the flight when non-airworthy 

mechanical, electrical, or structural conditions occur. 

While the operator’s UAS will not require an airworthiness certificate, operator is required to 

ensure that its aircraft is in an airworthy condition – based on compliance with the operating 

documents prior to every flight. As previously determined with Astraeus Aerial, Exemption 11062, 

relevant materials may be kept in a location accessible to the PIC in compliance with the 

regulations. 

14 CFR § 91.9 (b)(2) - Civil Aircraft Flight Manual, marking, and placard requirements 
Docket Operations April 11, 2015 Page 6 

14 CFR § 91.203 (a) & (b) - Civil aircraft: Certifications required 

As previously determined with Astraeus Aerial, Exemption 11062, relief from these sections are 

not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance 

with the regulations. 

14 CFR § 91.109 - Flight instruction: Simulated instrument flight and certain flight tests 

This regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

The controls for a UAS do not currently have a set of fully functioning dual controls. If a UAS’s 

pilot is being trained, the pilot performing the training would be directly supervising and could 

take over the controls from the pilot in training if the need arose. This would be similar to the 

technique of a "throw-over type" control wheel in some fixed wing aircraft. We feel that this 

technique meets the intent 91 .109 and provides an equivalent level of safety. 

14 CFR § 91.119 - Minimum safe altitudes

This regulation provides 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 this UAS 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-planning has been performed. Further, UAS aircraft operate at a very slow airspeed, 

and a low mass, and do not need as much space to operate safely, as outlined in 91.119. We 

believe the slower speed, smaller mass and careful pre-planning would provide an equivalent 

level of safety. Furthermore, Operator can place barriers and/or structures to sufficiently protect 

nonparticipating person from the UA or debris in the event of an accident. 

14 CFR § 9l.l21 - Altimeter settings

This regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. 

The UAS will normally be flying close to the ground, and in line of sight of the PIC or an observer. 

This line of sight operation will provide separation from other aircraft, obstructions and terrain 

providing an equivalent level of safety. Additionally, the altitude information generated by 

onboard GPS equipment installed on the aircraft will aid in estimating the altitude. 

Docket Operations April 11, 2015 Page 7

14 CFR § 91.151 - Fuel requirements for flight in VFR conditions 

This regulation provides that no person may begin a flight in an airplane under day- VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable 

reserve of energy to plan for a safe landing should there be a delay in landing. Given the close 

proximity to the ground station, the ability for the UAS to land in a very small space and the built 

in energy level monitoring of the UAS there is a resulting equivalent level of safety if the flight is 

planned to be completed with 20% battery energy remaining. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". 
14 CFR § 91.205 (b) – Powered civil aircraft with standard category U.S. airworthiness 

certificates: Instrument and equipment requirements 

Since the Operator’s UAS does not have a standard category U.S. airworthiness certificate, relief 

from 14 CFR § 91.205 is not necessary. 

14 CFR § 91.215 - ATC transponder and altitude reporting equipment and use 

Section 91.215 (b)(3) includes provision for aircraft not originally certificated with an enginedriven electrical system or which has not subsequently been certified with such a system 

installed. For UAS not equipped with a transponder, sub-paragraph (d)(3) authorizes requests for 

ATC authorized deviations made to the ATC facility having jurisdiction over the concerned 

airspace within the time periods specified. For operation of an aircraft that is not equipped with a 

transponder, the request must be made at least one hour before the proposed operation. 

14 CFR § 91.401 – 91.417 – Maintenance, preventive maintenance, and alterations 

This regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Operator believes that 

adherence to their documents containing preflight and post- flight checks for the UAS is sufficient 

to ensure that safety is not adversely affected. 

Respectfully, 

Daniel M. Foard - President

Cameron J. Foard Vice President

Videophotog Productions

256 Tropic BLVD E.

Largo, FL 33770