104 West Jersey Avenue

Brandon, FL 33510

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE 

Room W12-140 

West Building Ground Floor September 23, 2015

Washington, D.C. 20590-0001 

Reference: DroneVU Studios Petition for Section 333 Exemption

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), DroneVU 

Studios is petitioning for an exemption from the Federal Aviation Regulations and other 

rules/statutes pertaining to unmanned aircraft systems. Section 333 of the FMRA addresses 

special rules for certain unmanned aircraft systems and grants the FAA authority to allow for the 

safe operation of certain unmanned aircraft systems (UAS) within the national airspace. 

DroneVU Studios can assist construction sites with ensuring the safety of the site adheres to 

current safety guidelines, assist real estate professionals with effectively marketing their listings, 

assist with inspections in difficult and hazardous location, and assist businesses throughout the 

Florida area with reaching their target audience using the latest cutting edge aerial photography 

technology.

DroneVU Studios is comprised of pilots, photographers, and videographers with years of 

photography and videography experience which can be used to help local businesses more 

effectively market their products, services, and capabilities to potential future customers.

DroneVU Studios has safely created extensive complimentary aerial photography and aerial video 

footage throughout the Florida, Georgia, and North Carolina areas for educational and 

recreational purposes. We have combined experience of over 1,000 hours operating remotely 

controlled and remotely piloted terrestrial and aerial systems.

Obtaining an exemption would provide DroneVU Studios with the ability to meet an urgent need 

in the advertising community by creating aerial photography and aerial videography footage that 

customers could use to give them a marketing edge in a highly competitive environment.

Currently, the FAA does not allow civil UAS operations (meaning operations other than public 

aircraft operations or model aircraft / “hobbyist” activities which include research and 
U.S. Department of Transportation 

September 23, 2015

Page 2 of 15 

development); therefore DroneVU Studios has not been able to commercialize it’s aerial 

photography services to real estate, construction, and other Florida businesses. Approving this 

exemption would allow local American businesses to capitalize on the benefits that modern 

UASs can provide by giving DroneVU Studios the approval it needs to begin commercial 

operations.

14 CFR 11.81 (a) – Name and address of the Petitioner:

DroneVU Studios

104 West Jersey Avenue

Brandon, FL 33510

Phone: 727-403-1085

E-mail: info@dronevustudios.com

14 CFR 11.81 (b) – Exemptions Requested: 

The FAA considers unmanned aircraft as “aircraft” flown by a “pilot” regardless of the location of 

the pilot. All aircraft and pilots must comply with applicable sections of Title 14 of the Code of 

Federal Regulations (14 CFR) and other rules/regulations to operate within the National 

Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFR as the 

regulations were written prior to the consideration of small UAS integration within the national 

airspace. Therefore DroneVU Studios is requesting an exemption from certain parts of 14 CFR 

cited below, in addition to such further exemptions and relief as the FAA may determine is 

necessary to permit the operations described herein. 

14 CFR Part 21 Subpart H – Airworthiness certification 

14 CFR Part 45.23 (b) – Display of marks; general 

14 CFR Part 61.113 (a) and (b) – Private pilot privileges and limitations: Pilot in command 

14 CFR Part 91.7 – Civil Aircraft Airworthiness 

14 CFR Part 91.9 (b) – Civil aircraft flight manual, marking and placard requirements 

14 CFR Part 91.109 – Flight Instruction 

14 CFR Part 91.119 – Minimum safe altitudes 

14 CFR Part 91.121 – Altimeter settings 

14 CFR Part 91.151 – Fuel requirements for flight in VFR conditions 

14 CFR Part 91.203 (a) and (b) – Civil Aircraft; Certifications Required 

14 CFR Part 91.405 – Maintenance required 

14 CFR Part 91.407 – Operation after maintenance, preventive maintenance, rebuilding or 

alteration 

14 CFR Part 91.409 – Inspections 

14 CFR Part 91.417 – Maintenance Records 

U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d) 
U.S. Department of Transportation 

September 23, 2015

Page 3 of 15 

14 CFR Part 11.81 (c) – The extent of relief DroneVU Studios seeks, and the reason 

DroneVU Studios seeks the relief: 

DroneVU Studios seeks relief pursuant to this exemption from applicable parts of the Federal 

Aviation Regulations and other rules/regulations to the extent necessary to permit commercial 

civil flight operations within the national airspace. DroneVU Studios seeks authorization to 

conduct small UAS flight operations within the perimeters of this exemption request. 

14 CFR Part 21 Subpart H (Airworthiness Certificates)

DroneVU Studios seeks to utilize the DJI Inspire 1, and DJI Phantom 3, and the DJI Phantom 2 

UAS platforms under this exemption request. 

These UAS platforms have already been approved under previous Section 333 exemption

requests as evidenced by Sydor Aerial Photography LLC’s exemption approval (Exemption 

Number 11930). These platforms have a proven safety record and have demonstrated that its 

operations would not adversely affect safety compared to similar aircraft that have been issued 

an airworthiness certificated under 14 CFR Part 21, Subpart H. Should the FAA approve this 

exemption request and determine that an airworthiness certificate is not required, noise 

certification and testing under 14 CFR Part 36 will also not be required for these UAS platforms 

for the term of the exemption. 

14 CFR Part 45.23 (b) (Display of Marks: General)

DroneVU Studios, as the petitioner seeks relief from Part 45.23 (b) requiring markings on certain 

sections of the aircraft and markings of a certain size. DroneVU Studios clearly identify the 

company, and provide contact information as large as possible on all UAS platforms approved in 

this exemption due to the UAS small size. 

14 CFR Part 61.113 (a) and (b) (Private Pilot Privileges and Limitations: Pilot in Command) Part 

61.113 (a) states that no person who holds a private pilot certificate may act as pilot in 

command 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 or an aircraft. Part 61.113 

(b) states that 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. Within the Grant of Exemption Regulatory Docket No. FAA-2014-0352, 

the FAA stated that it had to determine the level of pilot certificate appropriate for that proposed 

operation. The FAA said within the Grant that it considers the overriding safety factor to be the 

airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and 

model experience and UAS testing. DroneVU Studios agrees with this determination; however 

due to the expense and extensive time required to either obtain a private or sport pilot’s license 

we request consideration of a 360 day temporary airman certificate in accordance with § 63.13

to allow DroneVU Studios time to hire a private, sport or commercial pilot or time to obtain such 

a designator by one of our existing employees.
U.S. Department of Transportation 

September 23, 2015

Page 4 of 15 

14 CFR Part 91.7 (Civil Aircraft Airworthiness)

This regulation states that (a) No person may operate a civil aircraft unless it is in airworthy 

condition and (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 

unairworthy mechanical, electrical, or structural conditions occur. This exemption would not be 

necessary should the FAA approve the exemption for 14 CFR Part 21 Subpart H. If DroneVU 

Studio’s UAS is not required to obtain an airworthiness certificate, then this would not apply; 

however DroneVU Studios would maintain the UAS and the PIC would deem the UAS safe for 

flight operations and discontinue any flight if any mechanical, electrical, or structural problem 

arose. 

14 CFR Part 91.9 (b) (Civil Aircraft Flight Manual, marking and placard requirements) and 14

CFR Part 91.203 (a) and (b) (Civil Aircraft; Certifications Required)

This regulation states that no person may operate a U.S. registered civil aircraft-(1) For which an 

Airplane or Rotorcraft Flight Manual is required by Part 21.5 of 14 CFR unless there is available 

in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided 

for in 14 CFR Part 121.141 (b); and (2) For which an Airplane or Rotorcraft Flight Manual is not 

required by 14 CFR Part 21.5, unless there is available in the aircraft a current approved 

Airplane or Rotorcraft Flight Manual, approved manual material, markings and placards or any 

combination thereof. Based on the FAA’s Memorandum titled, “Interpretation regarding whether 

certain required documents may be kept at an unmanned aircraft’s control station”, dated 

August 8. 2014, DroneVU Studios feels that requesting relief from these regulations may not be 

necessary. DroneVU Studios will have in its possession, on site, the UAS manufacturer’s 

flight/operations manual and registration paperwork. 

14 CFR Part 91.109 (Flight Instruction)

This regulation relates to civil aircraft with dual controls or throw over controls for flight training. 

DroneVU Studios seeks relief from this regulation in that our UAS platforms do not have dual or 

throw over controls for flight instruction. DroneVU Studios has provided all training and 

operational documents for all of our UAS platforms, the DJI Inspire 1, DJI Phantom 2, and DJI 

Phantom 3. DroneVU Studios evaluates the qualification of our pilots based on their experience 

with the UAS to be operated and verifies this through manufacturer and DroneVU Studios’-

supplemental training (from DroneVU Studios’ lead PIC). 

14 CFR Part 91.119 (b) and (c) (Minimum Safe Altitudes: General)

Per the regulation, except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. (b) Over 

congested areas. Over any congested area of a city, town, or settlement, or over any open air 

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

radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. In those areas, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 
U.S. Department of Transportation 

September 23, 2015

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DroneVU Studios does not request relief from (a) as we feel that our UAS can make an 

emergency landing without undue hazard to persons or property on the ground if its power unit 

fails due to its size and operating parameters. DroneVU Studios is seeking relief from (b) and (c) 

because the focus of our flights will be objects on the ground. Properly framing, and filming 

properties on the ground will require us to fly significantly lower than 500 feet, but we would not 

operate at an altitude that would create any undue hazard to persons or property on the surface. 

14 CFR Part 91.121 (Altimeter Settings)

This regulation states that:(a) Each person operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating—(1) Below 18,000 feet MSL, to—(i) The current reported altimeter setting of a 

station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within 

the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of 

an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the 

elevation of the departure airport or an appropriate altimeter setting available before departure; 

or (2) At or above 18,000 feet MSL, to 29.92′′ Hg.(b) The lowest usable flight level is determined 

by the atmospheric pressure in the area of operation as shown in the following table: 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight 

level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the 

appropriate number of feet specified below, according to the current reported altimeter setting: 

Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 
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September 23, 2015

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28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

27.41 through 26.92 3,000

Although DroneVU Studios will not have a typical aircraft barometric altimeter onboard the UAS, 

our intention is to operate within VLOS and at or below 400 feet AGL. This, in combination with 

our UAS’s capacity will provide altitude information to both the PIC and mission 

specialist/planner via a telemetric data feed which downlinks from the UAS to a ground based 

display. Prior to each flight the UAS PIC and mission specialist/planner will confirm altitude 

accuracy prior to launch. 

14 CFR Part 91.151 – Fuel Requirements for Flight in VFR Conditions

According to this regulation, (a) No person may begin a flight in an airplane under VFR 

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— (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (b) 

No person may begin a flight in a rotorcraft under VFR 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, to fly after that for at least 20 minutes. 

DroneVU Studios seeks relief from Part 91.151 (a.1) and (b), as its UAS does not carry fuel 

onboard and is powered via battery. DroneVU Studios’ UAS platforms all weigh less than 7lbs, 

operates at slow speeds and within VLOS in VMC conditions. DroneVU Studios intends to 

terminate flights after 20 minutes or with 20% remaining battery power (whichever occurs first). 

DroneVU Studios does not seek an exemption from Part 91.151 (a)(2) as UAS operations will 

be conducted during the daytime VMC (visual meteorological conditions). 

14 CFR Part 91.203 (a) and (b) – Civil Aircraft; Certifications Required

This regulations states that (a) Except as provided in §91.715, no person may operate a civil 

aircraft unless it has within it the following: (1) An appropriate and current airworthiness 

certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a 

special flight permit, a copy of the applicable operations specifications issued under §21.197(c) 

of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of 

this chapter containing that portion of the operations specifications issued under §21.197(c), or 

an authorization under §91.611) must have on it the registration number assigned to the aircraft 

under part 47 of this chapter. However, the airworthiness certificate need not have on it an 

assigned special identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special identification 

number, that has been affixed to an aircraft, may only be obtained upon application to an FAA 

Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, 

for operation within the United States, the second copy of the Aircraft registration Application as 

provided for in §47.31(c), or a registration certification issued under the laws of a foreign 
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September 23, 2015

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country. (b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Should the FAA allow for the exemption of 14 CFR Part 21, DroneVU Studios would not need an 

exemption from this regulation, as an airworthiness certificate would not be required; however 

since that exemption has not been received to date, DroneVU Studios seeks relief from this 

regulation. DroneVU Studios’ UAS will have the appropriate documentation available upon 

request. 

14 CFR Part 91.405 – Maintenance required

According to this regulation, each owner or operator of an aircraft—(a) Shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, except 

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter; (b) Shall ensure that maintenance personnel make appropriate entries in the 

aircraft maintenance records indicating the aircraft has been approved for return to service; (c) 

Shall have any inoperative instrument or item of equipment, permitted to be inoperative by 

§91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required 

inspection; and (d) When listed discrepancies include inoperative instruments or equipment, 

shall ensure that a placard has been installed as required by §43.11 of this chapter. DroneVU 

Studios seeks relief from this regulation because alternate UAS inspection requirements are 

needed. DroneVU Studios will follow UAS manufacturer requirements regarding maintenance 

via the manufacturer’s maintenance schedule. DroneVU Studios will document all maintenance, 

overhaul, replacement, and inspection requirements, as well as any preflight inspection 

procedures that account for discrepancies not already covered in the manufacturer’s manual; 

documentation of maintenance records and will partner with the UAS manufacturer to develop 

UAS technician qualification criteria. 

14 CFR Part 91.407 – Operation after maintenance, preventive maintenance, rebuilding or

alteration

Per this regulation, (a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless— (1) It has been approved for return to 

service by a person authorized under §43.7 of this chapter; and (2) The maintenance record 

entry required by §43.9 or §43.11, as applicable, of this chapter has been made. (b) No person 

may carry any person (other than crewmembers) in an aircraft that has been maintained, rebuilt, 

or altered in a manner that may have appreciably changed its flight characteristics or 

substantially affected its operation in flight until an appropriately rated pilot with at least a private 

pilot certificate flies the aircraft, makes an operational check of the maintenance performed or 

alteration made, and logs the flight in the aircraft records. (c) The aircraft does not have to be 

flown as required by paragraph (b) of this section if, prior to flight, ground tests, inspection, or 

both show conclusively that the maintenance, preventive maintenance, rebuilding, or alteration 

has not appreciably changed the flight characteristics or substantially affected the flight 

operation of the aircraft. 
U.S. Department of Transportation 

September 23, 2015

Page 8 of 15 

DroneVU Studios seeks relief from this regulation, and requests that the FAA adopt an 

alternative version that is applicable to UAS operations. A DroneVU Studios-approved UAS 

technician or the UAS manufacturer will approve the UAS to return to service/operation after it 

has undergone maintenance, rebuilding or alteration. The UAS PIC may approve the UAS for 

return to service after performing any preventive maintenance. DroneVU Studios will keep UAS 

maintenance records that contain the following information: name of the person performing the 

maintenance, description of work performed, and date of work completion/returned to service. 

14 CFR Part 91.409 – Inspections

According to this regulation, (a) Except as provided in paragraph (c) of this section, no person 

may operate an aircraft unless, within the preceding 12 calendar months, it has had—(1) An 

annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by §43.7 of this chapter; or 2) An inspection for the issuance of 

an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed 

under paragraph (b) of this section may be substituted for any inspection required by this 

paragraph unless it is performed by a person authorized to perform annual inspections and is 

entered as an “annual” inspection in the required maintenance records. (b) Except as provided 

in paragraph (c) of this section, no person may operate an aircraft carrying any person (other 

than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft 

which that person provides, unless within the preceding 100 hours of time in service the aircraft 

has received an annual or 100-hour inspection and been approved for return to service in 

accordance with part 43 of this chapter or has received an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter. The 100-hour limitation may 

be exceeded by not more than 10 hours while en route to reach a place where the inspection 

can be done. The excess time used to reach a place where the inspection can be done must be 

included in computing the next 100 hours of time in service. (c) Paragraphs (a) and (b) of this 

section do not apply to— (1) An aircraft that carries a special flight permit, a current 

experimental certificate, or a light-sport or provisional airworthiness certificate; (2) An aircraft 

inspected in accordance with an approved aircraft inspection program under part 125 or 135 of 

this chapter and so identified by the registration number in the operations specifications of the 

certificate holder having the approved inspection program; (3) An aircraft subject to the 

requirements of paragraph (d) or (e) of this section; or (4) Turbine-powered rotorcraft when the 

operator elects to inspect that rotorcraft in accordance with paragraph (e) of this section. 

DroneVU Studios seeks relief from this regulation, in that DroneVU Studios will follow the 

guidance included in the UAS manufacturer’s maintenance schedule as attached. 

 

14 CFR Part 91.417 – Maintenance Records

According to this regulation, (a) Except for work performed in accordance with §§91.411 and 

91.413, each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: (1) Records of the maintenance, preventive 
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September 23, 2015

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maintenance, and alteration and records of the 100-hour, annual, progressive, and other 

required or approved inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A 

description (or reference to data acceptable to the Administrator) of the work performed; and (ii) 

The date of completion of the work performed; and (iii) The signature, and certificate number of 

the person approving the aircraft for return to service. (2) Records containing the following 

information: i) The total time in service of the airframe, each engine, each propeller, and each 

rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, 

including the time since the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. (v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive involves recurring action, 

the time and date when the next action is required. (vi) Copies of the forms prescribed by 

§43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. (b) The owner or operator shall retain the following records 

for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 year after the work is 

performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a 

registered owner or operator under §43.11 of this chapter shall be retained until the defects are 

repaired and the aircraft is approved for return to service. (c) The owner or operator shall make 

all maintenance records required to be kept by this section available for inspection by the 

Administrator or any authorized representative of the National Transportation Safety Board 

(NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of 

this section for inspection upon request of any law enforcement officer. (d) When a fuel tank is 

installed within the passenger compartment or a baggage compartment pursuant to part 43 of 

this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner 

or operator. 

DroneVU Studios seeks relief from this regulation and requests an exemption. All maintenance 

and alterations will be properly documented in the each UAS aircraft records. DroneVU Studios 

will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, 

inspection and life limit requirements. All maintenance, preventive maintenance, alterations, 

status of replacement/overhaul component parts, and the total time in service of the UAS will be 

recorded and documented. DroneVU Studios will comply with all manufacturer safety bulletins. 

U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d)

6(d) Certificates of Waiver or Authorization (COA)-Emergency and Urgent Applications: The 

FAA must ensure procedures are available to accommodate real-time applications that will 

directly support emergency and law enforcement-type operations. UA Operations that reduce 

safety must not be approved in any case. (1) An emergency UAS COA may be considered 
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September 23, 2015

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when all of the following conditions apply: (a) There is a situation of such distress or urgency 

that the possibility of loss of life is great. (b) Manned flight is not possible or practicable due to a 

hazard or the operation cannot be conducted safely with manned flight, or manned assets are 

not available. (c) The proposed proponent and UAS are operating under a current approved 

COA. Note- Requests for UAS COAs that fall outside of these perimeters must be processed 

through the normal online COA application process. (2) Emergency UAS COAs will not be 

considered for: (a) Demonstration flights. (b) Flights to test capabilities. (c) Training. (d) Flights 

in Class B airspace. (e) Flights over populated areas. 

DroneVU Studios seeks an exemption from the normal FAA UAS Civil COA Request mandated 

by a Section 333 Exemption filing and the current Emergency COA process. During a 

catastrophe event, the exact timeframe and location is not known ahead of time; therefore, 

DroneVU Studios could not abide by the current COA process and would need an exemption 

from the normal COA process as well as the current Emergency COA process. DroneVU 

Studios would notify the local FSDO of the affected area immediately, apply for an amended 

Emergency COA (as granted by this exemption) and would notify any Incident Command or first 

responders for approval and coordination and would not interfere with first responders’ activities. 

Through this request, DroneVU Studios is seeking relief from U.S. DOT-FAA-Air Traffic 

Organization Policy Notice N JO 7210.873 (6.d)1(a), 1(c), 2(d) with ATO approval, and 2(e) of 

the COA process stated above. 

 

14 CFR Part 11.81 (d) – The reasons why granting DroneVU Studios’ request would be in 

the public interest; that is, how it would benefit the public as a whole: 

Granting the exemption for DroneVU Studios would allow the organization to safely and 

efficiently conduct small UAS flight operations to assist local businesses more effectively 

advertise their services, home owners to more quickly sell their homes, home buyers to better 

visual their potential future home, construction companies to more safely manage their 

construction sites, and could more safely and effectively inspect cell phone towers, railroad 

tracks, pipelines, and other structures that could pose a risk to public safety in the event of a 

failure. Without this exemption, DroneVU Studios would be restricted to ground only operations 

which would not have the benefits of UAS efficiency in terms of service, safety, and advertising 

appeal. 

14 CFR Part 11.81 (e) – The reasons why granting the exemption would not adversely 

affect safety, or how the exemption would provide a level of safety at least equal to that 

provided by the rule from which DroneVU Studios seeks the exemption: 

DroneVU Studios requests that the exemption be granted with the following limitations and 

operational conditions. These limitations and conditions will provide an enhanced level of safety 

and will be the guiding principles when DroneVU Studios is conducting operations under this 

exemption: 
U.S. Department of Transportation 

September 23, 2015

Page 11 of 15 

A. The small unmanned aircraft systems maximum take-off weight will be less than 55 lbs. 

DroneVU Studios is willing to have its authorization restricted below the 55 lb. threshold 

to the operating weight of the unmanned aircraft identified. The UAS platforms that 

DroneVU Studios is seeking to utilize through this exemption is currently operating safely 

within the national airspace pursuant to several COAs granted by the FAA to Tierra 

Antigua Realty, Sydor Aerial Photography, and other public entities. One these COAs 

was for the use of the DJI Phantom 2 -to provide aerial imagery for real estate properties 

in the Arizona area. Other COAs have been approved for this particular platform through 

other public entities, which demonstrates the confidence that the FAA has for this 

manufacturer’s operational and safety protocol. DroneVU Studios would operate in 

accordance with the manufacturer’s flight manuals, maintenance schedules, and training 

documents. 

B. All pilot in command (PIC) and visual observers (VO) will possess an FAA certified 

private pilot’s license or operate the craft under a temporary airman certificate if so 

granted in accordance with § 63.13. This ensures that all PIC and VO have the 

knowledge regarding the Federal Aviation Regulations, Airspace, and other pertinent 

knowledge to conduct safe operations of small unmanned aircraft systems. All PIC and 

VO will be trained in detail for each of the unmanned aircraft system platform’s 

operations, systems and emergency procedures and passed every level of training on 

the platform and pass the manufacturer’s test if so provided which would be 

administered by the DroneVU Studios PIC. Training records will be kept at DroneVU 

Studios for every PIC and VO and will be available for review. Every PIC and VO will 

obtain an FAA Class 3 medical certificate or hold a valid driver’s license. 

C. Prior to conducting operations for a commercial customer, the PIC will have accumulated 

and logged, in a manner consistent with 14 CFR Part 61.51 (b), a minimum of 200 flight 

cycles and 25 hours of total time as a UAS pilot and at least 10 hours logged as a UAS 

pilot with a similar UAS type. The PIC will have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the make and model of the UAS to be utilized for 

operations and 3 take off and landings in the preceding 90 days. 

All flight operations will be coordinated and approved by the homeowner, construction

site authorized representative, commercial property authorized representative, or any 

authorized representative for the structure to be filmed in advance of DroneVU Studios’ 

arrival at the filming site via email or written authorization. The UAS will not be operated 

directly over any person, except authorized and consenting personnel at the site or 

unless the UAS is at sufficient altitude not to create a hazard to other people or property 

on the ground. 
U.S. Department of Transportation 

September 23, 2015

Page 12 of 15 

D. All flight operations will be operated at an altitude of no more than 400 ft above the 

ground (AGL) within daylight VFR conditions and within visual line of sight (VLOS). The 

UAS will be operated within VLOS of the PIC at all times. The UAS will remain clear and 

yield the right of way to all other manned operations and activities at all times. All 

operations will utilize at least one visual observer (VO) and the PIC and VO will be able 

to communicate verbally at all times. The UAS will not operate within 5 nm of any airport 

unless a letter of agreement with that airport’s management is obtained and the 

operation is conducted in accordance with a NOTAM, as required by a COA. All flights 

will be communicated to FAA Flight Service with posted NOTAMS prior to the flight(s). 

E. All flight operations will be conducted within line of sight of the pilot in command and 

visual observer(s). Maximum total flight time for each flight will be 20minutes or less in 

duration. All flight operations will be terminated when the aircraft has less than 20% 

battery life remaining. 

F. Flight operations and safety briefings will be conducted prior to all planned small 

unmanned aircraft system flights and will be mandatory for PIC and VO. Briefings will 

include weather reviews, take off, landing and aircraft performance data for those real 

time conditions, and full pre- and post-flight inspections/checklists and briefings for each 

specific unmanned aircraft system, including the ground control station being operated 

and account for any discrepancies (i.e. inoperable components, items or equipment that 

are not covered in the relevant preflight inspection sections of the operations manual.) 

Before conducting any flight, the radio frequency spectrum used for the operation and 

control of the UAS will comply with the FCC or other appropriate government oversight 

agency requirements. 

G. The UAS will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. 

The letter of agreement with the airport management will be made available to the 

Administrator or any law enforcement official upon request.

H. Any UAS that has undergone maintenance or alterations that affects the UAS operation 

or flight characteristics must undergo a functional test flight in accordance with the 

manufacturer’s recommendations. The PIC who conducts the test flight will make an 

entry in the UAS aircraft records of the flight. All maintenance and alterations will be 

properly documented in the aircraft records. DroneVU Studios will follow the UAS 

manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection and 

life limit requirements. All maintenance, preventive maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS will be
U.S. Department of Transportation 

September 23, 2015

Page 13 of 15 

recorded and documented. DroneVU Studios will comply with all manufacturer safety 

bulletins. 

I. In the event of a communication lost link, the UAS will return to a specific predetermined 

location and once the UAS is safely recovered, all flight operations will cease until any 

communication/data link issues are properly resolved. The UAS will abort the flight in the 

event of unpredicted obstacles or emergencies in accordance with the operator’s 

manual. 

J. Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA’s UAS Integration Office (AFS-80) within 24hrs. Accidents will be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.com. DroneVU Studios will suspend all flight operations until the 

incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided. 

14 CFR Part 11.81 (f) A summary the FAA can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption 

Petitioner: DroneVU Studios

Sections of 14 CFR and FAA regulations that DroneVU Studios seeks an exemption: 

14 CFR Part 21 Subpart H 

14 CFR Part 45.23 (b) 

14 CFR Part 61.113 (a) and (b) 

14 CFR Part 91.7 

14 CFR Part 91.9 (b) 

14 CFR Part 91.109 

14 CFR Part 91.119 

14 CFR Part 91.121 

14 CFR Part 91.151 

14 CFR Part 91.203 (a) and (b) 

14 CFR Part 91.405 

14 CFR Part 91.407 

14 CFR Part 91.409 

14 CFR Part 91.417 

U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d) 
U.S. Department of Transportation 

September 23, 2015

Page 14 of 15 

 (2) A brief description of the nature of the exemption you seek: 

DroneVU Studios seeks relief from the applicable parts of 14 CFR 21, 45, 61, 91 and U.S. DOTFAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d) as requested within this petition 

to allow DroneVU Studios to safely and efficiently conduct civil UAS flight operations to assist 

business owners, real estate professionals, construction site owners, in advertising their 

services, safely conducting construction operations, and safely inspecting in areas that could be 

hazardous or difficult for humans to inspect.

14 CFR Part 11.81 (g) – Any additional information, views or arguments available to 

support DroneVU Studios request: 

Granting this exemption for DroneVU Studios would allow the organization to safely and 

efficiently conduct small UAS flight operations to assist local businesses more effectively 

advertise their services, home owners to more quickly sell their homes, home buyers to better 

visual their potential future home, construction companies to more safely manage their 

construction sites, and could more safely and effectively inspect cell phone towers, railroad 

tracks, pipelines, and other structures that could pose a risk to public safety in the event of a 

failure. 

14 CFR Part 11.81 (h) – Request to exercise the privileges of the exemption outside the 

United States, the reason why the petitioner needs to do so: 

DroneVU Studios does not seek to exercise the privileges of this exemption, should it be 

granted, outside of the United States. Our request is strictly to be granted authority for civil UAS 

operations at locations within the national airspace system. 

Sincerely, 

Robert Ashe

Robert Ashe

Owner – DroneVU Studios