Gravity Pictures, LLC

Colter D Hansen

2438 Stafford Drive

Ammon, ID 83406

(307) 884-7771

29 September 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

SE Washington, DC 20590

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Gravity Pictures, operator of Small Unmanned Aircraft System (“sUAS”) equipped to 

conduct aerial photography and videography, News gathering, Aerial Surveying, and Closed set Video 

production hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to 

allow commercial operation of its sUASs, 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 333.1.

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined and 3) controlled. The proposed exemption, if granted, would allow Gravity Pictures, LLC 

to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all 

of the operational and safety requirements Congress has set forth in Section 333. Page 2. Gravity 

Pictures, LLC asks that if any part of this request is deemed not in compliance, that part be removed and 

process the remaining of this request as applicable.

Gravity Pictures, LLC plans to engage the capabilities of Unmanned Aerial Systems to offer high quality 

imagery for a variety of commercial, public, and residential uses including:

- Event Photography/Videography

- Real Estate Photography

- Agriculture purposes

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Closed set video production

- Aerial surveying

- News Gathering

- Ranch Observation

- Telecommunication Tower Inspections

- Search and Rescue

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. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations.

Small Unmanned Aircraft Systems are oftentimes seen as superior to helicopters due to the smaller 

devices, cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. We are petitioning for exemption to enable Gravity 

Pictures, LLC to operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 equipped with a two-axis 

camera gimbal and using a HighDef camera. These sUASs have a built-in capability to limit the height 

they fly above the ground, to limit the radius of the distance it flies from the operator. They also have 

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

and will land safely.

Aircraft Gross weights are less than 8 pounds with battery and camera payload.

A Pre-flight inspection will be performed by the PIC 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 manufacturer’s instruction manual and only 

manufacturer's authorized replacement parts will be used.

FCC Information

This transmitters 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 radio transmitters used for controlling the sUAS is wireless technology which has been tested and 

found to be compliant with the applicable regulations governing a radio transmitters in the 2.400GHz to 

2.4835GHz frequency range.

Antenna Separation Distance

When operating our transmitters, the PIC 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 PIC will maintain a driver’s license and at least 1 hour’s flying time and 3 takeoffs and landings 

within the previous 90 days in the type of UAS utilized in operations. The PIC will have at least 100 hours 

flying Radio Controlled Model Aircraft in the form of sUAS's for recreational use.

The PIC 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 PIC.

The Observers duties are;

 warning the PIC of any impending obstacles in the flight path of the sUAS.

 warning the PIC of any deviations in the planned flight path of the sUAS.

 warning the PIC should any unauthorized personnel appear in the area of the planned flight.

The Observer will have the authority to order the PIC to terminate the flight should he feel the flight 

cannot be conducted safely.

General Operating Standards

• Gravity Pictures, LLC will only operate its sUAS in line of sight of a pilot and 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 400 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 PIC 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 400 feet AGL. Weather minimums will be 3 miles visibility and 

a 1000 foot ceiling.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

• The sUAV will be programmed so that it will be operated at an altitude of no more than 400 feet AGL.

• 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 per battery cycle, this offers 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. Other options include manned aircraft, which proves to be more costly than many potential 

clients care 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 as well as mitigating risk by not 

carrying personnel for flight operations.

(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) All required permits will be obtained from state and local government prior to operation;

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Gravity Pictures, LLC 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 Phantom 2, DJI Phantom 3, 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 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.

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 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 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 6.1 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 91.205(a), (b), (c) Instrument and Equipment Requirements

This regulation provides a minimum set of instruments and equipment required for day and night VFR 

flight. Due to the small size of the sUAS it would be impossible to carry many of these instruments. 

91.205 (b) 4,5,6,7,8,13,14,16,17 are not applicable as the sUAS has no Reciprocating engines or seats. 

91.205 (b) 2,3,9 are provided on the hand held controller. 91.205(b) 1 is not applicable as the maximum 

available speed of the sUAS is less than the maximum required by this exemption and has no effect on 

performance. 91.205 (b) 10 is not applicable as the landing gear position can be verified visually before 

landing. 91.205 (b) 15 Due to the size it would be impossible for the sUAS to carry any known ELT. 

91.205 (c) Much of this equipment is too heavy to be carried by the sUAS. We feel that visual contact 

with the sUAS and indications provided via the controller that all critical information can be monitored.

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 onboard computer. All other maintenance will be performed by the manufacturer or their designated 

repair facility. 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

Gravity Pictures, LLC 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 Gravity Pictures, LLC ‘s 
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. Gravity Pictures, LLC 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 mentioned above, the sUASs which our company would use and under authorization by the US DOTFAA, is a small device less than 10 pounds, operated within the line of sight of the Pilot-in-Command 

(PIC), less than 400 feet above the ground and outside a 5 mile radius 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.

The sUAS have proven capability for controlled flight. They are devices offered for general sale on the 

market around the world and have 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 Gravity Pictures, LLC 

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. If any individual aspect of this request for exemption be unacceptable we ask that it be 

struck alone and the remainder of the exemption be allowed as requested.

Signed

Colter D. Hansen

Gravity Pictures, LLC