Forever Ready Productions, LLC 

465 S Main Street #304 

Memphis, TN 38103 

Scott@ForeverReadyLLC.com 

(cell) 901-729-9215 

July 24, 2015 

US Department Of Transportation

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and ReformAct of 2012(the reform 

act) and CFR Part 11, Forever Ready Productions, LLC, owner and operator of Small Unmanned 

Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations 

{FAR) listed below so that Forever Ready Productions, LLC may operate UASs commercially in 

airspace regulated by the FAA, as 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. 

 Forever Ready Productions, LLC is co-owned by Scott W Ready and Lauren M Ready. Forever 

Ready Productions, LLC will secure a PIC as operator with appropriate licensure as stipulated by the 

Section 333 exemption requirements. All operations performed will be performed with public’s safety 

and right to privacy safe-guarded at all times. 

As described below, the requested exception would permit the operation of 

light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for 

commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary 

of Transportation's ( the FAA Administrator's) responsibility to" establish requirements for safe 

operation of such aircraft systems in national airspace systems." Section 333(c), of the Reform 

Act. 

Forever Ready Productions, LLC video UASs are rotorcraft weighing less than 55 pounds 

including payload. (The DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire class) They 

operate at a speed less than 50 knots and have the capability to hover and move in the vertical 

and horizontal plane simultaneously. UASs have an auto return to launch point when battery 

power is under 25%. The UAS will operate within the line of sight with in a protected flight area 

as described below and at 200 feet AGL or less with an observer located close at hand as to 

make voice communication possible. These operations will not create a hazard to users of the 

nation airspace, public nor the environment. 

Forever Ready Productions, LLC respectfully requests the grant of an exception to the 

following specific sections of the Title 14 Code Federal regulations a11owing it to operate 

lightweight UASs for commercial use, 
14 CFR 21,subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 

91.119, 91.121,91.151,(a), 91.203(a) &{b},91.405(a),91.407(a)(1), 91.409(a)&(b). 

Forever Ready Productions, LLC submits this application in accordance with the Reform 

Act, 112 P.L. 95 331-334, seeking relief from any current applicable FAR’s operating to prevent 

Forever Ready Productions, LLC future commercial use of small UASs to operate in the national 

airspace system (NAS) as described below. The Reform Act section 332 provides for such 

integration of civil unmanned aircraft into our NAS as it is in the public’s interest to do so. 

Forever Ready Productions, LLC’s UASs meet the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of these UASs are expressly contemplated 

by the Reform Act. Forever Ready Productions, LLC would like to operate its light weight UASs 

prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such aircraft. 

The Reform Act direct the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace before completion of 

the rule making required under Section 332 of the Reform Act. In making this determination, 

the Secretary of Transportation is required to determine which UASs do create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

- The UASs size, speed, weight and operational capability 

- Operation of the UASs in close proximinity to airports and populated areas 

- Operation of the UASs within visual line of sight of the operator 

Reform Act 333(a). If the secretary determines that such vehicale “may operate safely 

in the national airspace system, the secretary shall establish requirements for the safe 

operation in national airspace” 

Forever Ready Productions, LLC video UASs are rotorcraft weighing less than 55 pounds 

including payload. (The DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire class) They 

operate at a speed less than 50 knots and have the capability to hover and move in the vertical 

and horizontal plane simultaneously. UASs have an auto return to launch point when battery 

power is under 25%. The UAS will operate within the line of sight with in a protected flight area 

as described below and at 200 feet AGL or less with an observer located close at hand as to 

make voice communication possible. These operations will not create a hazard to users of the 

nation airspace, public nor the environment. 

The very small nature of these UASs combined with the safe guards presented below, 

will allow for the safe operation greater than that envisioned by Congress for the FAA to 

establish and by exemption allow commercial operations of UASs to commence immediately. 

Also due to the size of UASs and the areas and altitudes they will operate approval of this 

exception presents no national security issues and absolutely minimal safety concerns which 

have been mitigated through our rigorous risk management process. Given the clear direction 

given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs 

verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial 

photography thereby benefiting the greater public's interest. Accordingly, the applicant 

requests that the FAA grant the requested exemption without delay. 

The following will be considered as the binding limitation on operations of Forever 
Ready Productions, LLC, 

1. Flights will only occur in the day time hours, 

2. Flights will be operated in the line of sight of the operator(PIC) and Observer,(VSO) 

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for 

flight" by manufacturers recommendations, 

4. The UASs will weigh less than 55 lbs., 

5. Flights will be operated at 200 feet AGL or less. 

6. Crew will be at a minimum of operator(PIC) and an observer and/or camera 

operator(VSO), 

7. Operator and crew will remain in contact during the flight operation, 

8. The UASs operator will perform a check of the flight area and make certain of the 

safety of all persons in the area, 

9. Consent will be obtained from all persons with in the video capabilities of the units to 

further reduce the chance of violating anyone's privacy. 

10.All required FAA clearances, will be obtained and distances from airports strictly 

observed. 

11.All UASs will have the capability to return automatically to the operator in a safe 

manner with the auto return function checked and working. 

12.When operated in conjunction with fishing vessels in the gulf, a chase boat will be 

assigned to operate the UASs at a safe distance from the main fishing boat. 

13. Flights will only operate in VFR conditions. 

14.UASs have a function on the control to tell operator the distance away from the 

operator and its battery power remaining. 

15. Flight team will communicate by voice and the use of two-way radio if the area is too 

great to hear voice from all team members. 

16.UASs will be used to video private outings and functions, boating, jet skiing, kayaking, 

fishing trips in the gulf area and sporting events from a safe distance. 

17.When operating over or near water the UASs will be equipped with flotation devices so 

that recovery can be made as to prevent lithium battery exposure to the water table. 

14 CFR part 21Subpart H: Airworthiness Certificate 14 CFR 91.7(a}, 91.203(a)(l) 

Subpart H,entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(l). The size, weight and defined area of 

operations for Forever Ready Productions, LLC UASs flights permits exception from Part 21 

because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both 

the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, 

speed,maneuverability and proximity to areas such as airports and dense populations. Forever 

Ready Productions, LLC meets or exceeds each of these elements 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for 

flights at or under 200 AGL to any UASs operator with a section 333 exemption. 

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These 

are inapplicable for the same reasons stated above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Forever Ready Productions, LLC 

operations center. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by FAR's this regulation is 

inapplicable. 

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of 
safety will be achieved by maintaining such certifications and registrations at Forever Ready 

Productions, LLC operations center. 

The FAA has previously issued exemptions to this regulation in Exemptions No's 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. Forever Ready 

Productions, LLC will only operate its UASs at or below 200AGL. They will be operated on a will 

defined AOR that has been carefully reviewed for hazards and minimizes the presence of any

persons not essential for these operations. Flights will only be over private property that the

owner has consented and all persons withinthis video area also give consent forthis

filming.Compared to flight operations of conventional and traditional aircraft or rotorcraft

weighingfar more than 50 lbs,operatingbelow 500 AGL with flammable fuel UASs operations

present a far smaller risk tothe public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the 

service of aerial photography wilI greatly enhance safety by reducing the overall risk associated 

with traditional aircraft. Traditional aerial photography requires large aircraft with flammable 

fuel to fly in close proximity of populated areas and people in general. 

With the use of small UASs of 55 lbs. or less,battery operated and fling below 200 feet AGL the 

risk of injury of people on the ground or the crew has been reduced or almost erased. The 

granting of the use of these small UASs by Forever Ready Productions, LLC will give the people 

another avenue to express themselves and to have a video record to share with family and 

friends forever. 

Granting Forever Ready Productions, LLC the above exemption will allow for the 

expansion of UAS systems into the future for the safe conduct of free enterprise and the 

enjoyment of the masses. 

Forever Ready Productions, LLC respectfully requests the FAA grant its exception without 

delay. The FAA has the authority to issue the exemption sought by Forever Ready Productions, 

LLC pursuant to the Federal Aviation Act, 85 P.L. 726 {1958) as amended {the ACT). 

 Respectfully submitted, 

 Scott W Ready 

 Owner 

 Forever Ready Productions, LLC 

 
INTERESTS OF THE PETITIONER 

The objective is to expand a small video production business into Aerial Video and Photography Service

to provide high quality imaging for a variety of commercial and public uses, specifically targeting:

- Wedding and Special Events coverage 

- Local news coverage

- Video for Real Estate agents 

- Coverage of Sporting Events

- Interviews of individuals

UAS/AERIAL EQUIPMENT OF THE PETITIONER

- DJI Phantom 2 Vision+ 

- DJI Phantom 3 

- DJI Inspire 1 

- DJI Inspire class UASs 

Forever Ready Productions, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight 

to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location information to the PIC via 

the linked monitor (smart phone/tablet devices)