Dec 17th, 2015.

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591

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

Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 

91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b).

Applicant:

Marc Rotse

Owner

Moving Picture Weddings and Lightbox Filmworks

825 NW Glisan St

Portland OR 97209

marc@movingpictureweddings.com

(818) 434-1830

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Marc Rotse, operator of an 

Unmanned Aircraft System (UAS), hereby apply, on behalf of Moving Picture Weddings and Lightbox 

Filmworks, for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UAS, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 

91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would 

allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and 

photography real estate purposes and events.

Commercial operation of an UAS, as described herein, which are equipped with camera and sensors, would 

operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate, golf courses, 

agriculture/livestock, land surveying and other related professional activities.

• Aerial video and/or photography for public and/or private use including public and private events. 

As described fully below, the requested exemption would permit the operation of a 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 responsibilities 

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

As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a DJI Inspire 1

UAS. We will operate a UAS, the DJI Inspire 1, Model T600, which is comprised of an unmanned aircraft 

an attached 4K camera and a transportable ground station.

The Inspire 1 is a quad-copter with a gross weight of 6.47lbs. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed of 22 m/s. It will be operated 

over various areas, primarily Portland OR, to augment real estate listing videos, capture event aerial video 

and photography, and related business operations. 
UAS Operating Parameters 

We will abide by the following additional operating conditions under this exemption, which ensures a level 

of safety at least equal to existing rules: 

 operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in 

direct line of sight visual observation; 

 obtain permission from the owner/controller of any vessels, vehicles and structures when 

operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we 

will conduct a safety assessment of the risk of operating closer to those objects and determine that 

it does not present an undue hazard; 

 operate the UAS for 10-15 minutes per flight; 

 land UAS prior to the manufacturer’s recommended minimum level of battery power; 

 operate UAS during daylight hours only within visual line of sight (VLOS); use the UAS’ global 

positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost; 

 conduct all operations under the flight safety protocols (including posting a warning sign 

reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the 

operating documents and will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols; 

 contact respective airports if operations will be within 5 miles to advise them of his estimated 

flight time, flight duration, elevation of flight and other pertinent information; 

 always obtain all necessary permissions prior to operation; have procedures in place to abort 

flights in the event of safety breaches or potential danger; 

 only operate in safe environments that are strictly controlled, are away from power lines, elevated 

lights, airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts 

and through obtaining information regarding congested areas from the local Flight Standards 

District Office (FSDO); 

 conduct extensive preflight inspections and protocols, during which safety carries primary 

importance (reference Inspire User Manual). 

Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists 

simulating flights for future commercial use to gain familiarization with the characteristics of the UAS’ 

performance under different temperature and weather conditions. 

Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot 

with a multi-rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS 

pilot operating the same make and model of UAS to be used for operations. In addition to the hour 

requirements, the PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currency 

purposes) prior to any flight. 

Specific Exemptions Requested 

Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption 

from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §91.203(a) and (b) (Certifications 

required), subject to certain conditions and limitations,is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333). 

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 

Regardless of this, we can mark the UAS in the largest possible lettering by placing the word 
“Experimental” on its fuselage as required by § 45.29(f) so that anyone will see the markings. 

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an 

airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is 

inapplicable. 

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety 

precaution we will perform a preflight inspection of the UAS before each flight as outlined in the attached 

operating documents. 

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however 

since there are no pilots or passengers on board the aircraft and given its size, this regulation is 

inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight 

manual with the UAS ground station. 

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, 

but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our 

UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away 

from the public and traffic, thus “providing a level of safety at least equivalent to or below those in relation 

to minimum safe altitudes.” Given the size, weight, maneuverability, and speed of the UAS, an equivalent 

or higher level of safety will be achieved. 

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes 

electronic GPS with a barometric sensor. 

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions.The UAV is 

100% electric and two low battery alerts are issued - per the operating documents, the UAV will be landed 

at the first alert. Also, our flights will last only 10-15 minutes each, and the UAS has an automated 

function, which results in immediate landing when a low battery is detected. 

The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough 

power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 

30% battery power remaining. 

Public Interest 

Aerial photography and videography for real estate and events are proven strategies to enhance marketing 

efforts and increase business success. The industry is not new. However, until recently it was conducted 

through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting 

this exemption I would be able to provide affordable services. 

Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel 

when compared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to 

the environment economic growth by providing information to companies and the public looking to 

relocate or build in the metro areas we service. Public and private events serviced by our business enhance 

vibrancy and add culture to the community and its citizens. 

Summary 

We will comply with all of the following conditions and limitations should this exemption be provided:

1) Operations will be limited to the following aircraft described in the operating documents, which is a 

quad-rotor aircraft weighing 6.47 pounds: DJI Inspire 1 Unmanned Aircraft System.
2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above ground level(AGL), All 

altitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command(PIC) at all 

times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight 

(VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC 

will be designated before the flight and will not transfer his or her designation for the duration of the flight. 

The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. Any revisions to the operating documents will be presented to the 

Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated 

until the necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The Ground Control Station will be included in the preflight inspection. All maintenance and 

alterations will be properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts 

the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the operating 

documents.

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

inspection, and life limit requirements. 

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance with the 

operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, 

including total flight hours, description of work accomplished, and the signature of the authorized person 

returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a 

current third-class medical certificate. The PIC will also meet the flight review requirements specified in 14 

CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15) Prior to operations conducted for the purpose of aerial videography/photography and for real estate 

listing videos and public and private events and similar operations, the PIC will have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

16) Prior to operations conducted for the purpose of aerial videography/photography and for real estate 

listing videos and public and private events and similar operations, the PIC will have accumulated and 
logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the 

make and model of the UAS to be used in operations. The PIC will accomplish 3 take-offs and landings in 

the preceding 90 days.

17) The PIC will not operate the UAS for the purpose of aerial videography/photography and for real estate 

listing videos and public and private events and similar operations, unless the PIC has demonstrated and 

logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be 

conducted under visual meteorological conditions (VMC).

19) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current 

FAA-published aeronautical chart.

20) The UA will 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.

21) If a UA loses communications or loses its GPS signal, it will return to a predetermined location within 

the planned operating area and land or be recovered in accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the 

operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% 

battery power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) 

prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation.

25) Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents will be made available to the 

Administrator or any law enforcement official upon request. 

27) The UA will remain clear and yield the right of way to all manned aviation operations and activities at 

all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas. 

30) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or 

debris in the event of an accident. We will ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipatingpersons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, 

vehicles or structures has granted permission and the PIC hasmade a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard 

to those persons per § 91.119(a).

31) All operations will be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

32) 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 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

The DJI Inspire 1 manual can be viewed at this link http://www.dji.com/product/inspire-1/info#downloads

If you have questions or need additional information, please contact me at 

marc@movingpictureweddings.com or (818) 434-1830. 

Thank you,

Marc Rotse