Air Cam Shots’ 333 Petition

August 3, 2015

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Erick F. Larsen

Consultant to 

Air Cam Shots

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com

August 3, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., 

SE Washington, DC 20590

Re: Donny Robert Melara dba Air Cam Shots’ Request (Petition) for Exemption from Certain 

Regulations per Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

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

C.F.R. Part 11, Donny Robert Melara (Donny or Donny Melara) dba Air Cam Shots (Air Cam Shots , 

Petitioner, or Operator) hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow business use (commercial operation) of his small unoccupied 

(unmanned) aerial systems (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. INTRODUCTION

Petitioner, Donny Melara dba Air Cam Shots, is a United States born citizen, with the following 

contact information, operating worldwide and at:

AIR CAM SHOTS

1317 N. SAN FERNANDO BLVD. #328

BURBANK, CA 91504

Phone: (323) 327-3016

donny@aircamshots.com

www.aircamshots.com

Petitioner, Donny Melara dba Air Cam Shots, has been building and operating model aircraft and 

UAS for more than a decade. Serving as Chief Pilot, Shooter, and Co-founder of Air Cam Shots,

Donny has a passion for UAS and photography. Donny merged the two and has become one of the 

most skilled UAS, RC Flyer-Shooters in the business. His additional skills include research and 

development, having built over 200 high performance unoccupied (unmanned) aircraft (UA) 
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ranging from 195 mph Jets to Aerobatic Planes and Helicopters. He is has received many awards for 

competing in tournaments internationally. He speaks both English and Spanish fluently. He 

currently maintains a duly issued US Passport and a Driver’s License issued by the California 

Department of Motor Vehicles.

Petitioner has incorporated UAS operations into his existing businesses. Small business is the 

backbone of America. Through years of aircraft and UAS commercial and hobbyist experience, 

petitioner has developed numerous diverse clients in need of UAS training and for safe and lawful 

commercial UAS aerial data collection (ADC) services. Petitioner’s small UAS business will provide 

new jobs and an increased level of safety to clients currently in need of UAS training and ADC 

commercial services. Existing FAA UAS policy bars Petitioner from providing UAS training and ADC 

commercial services in the absence of the requested exemptions. 

Petitioner, Air Cam Shots, provides training for unoccupied (unmanned) aircraft (UA) to 

recreational, commercial, governmental, Emergency Management Agencies (EMA) and entities. 

Petitioner’s main priority is to promote safety in the national airspace. Air Cam Shots’ training 

includes e.g. obeying FAA regulations, joining the AMA, understanding how to fly UA, and making 

sure that all safety standards are being met.

Air Cam Shots recognizes the enormous potential of UAS but also recognizes the need for due 

diligence and responsibility on the part of all persons that will fly UAS to ensure the safety of the 

National Airspace (NAS). Air Cam Shots is assisting with the integration of UAS into the NAS by 

educating new users of this technology. 

Air Cam Shots’ UAS training is based on the military model of classroom instruction, trainer 

demonstration, and user hands on performance. Understanding and proficiency is determined by 

knowledge and proficiency testing.

Instruction includes the following:

 FAA regulations

 Limitations and restrictions of where and when users can fly

 Liability for flying irresponsibly

 Pre, during, and post flight safety check lists

 Benefits of Academy of Model Aeronautics (AMA) membership.

 User types and details (commercial, public, and recreational)

 Identification of No fly zones 

 Review of knowbeforeyoufly.com

 Similar safe UA operating principles and techniques

Similar exemptions have been granted to other UAS training operations, including Exemption No. 

11625 Regulatory Docket No. FAA–2015–0551 and generally, exemptions 2689F, 5745, 10673, and 

10808.
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Petitioner also seeks to operate UAS to conduct aerial data collection (ADC) which includes any 

remote sensing and measuring by an instrument(s) aboard the unmanned aircraft (UA). Examples 

include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, 

RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of 

data by instruments aboard the UA.

In particular Petitioner seeks authorization to conduct commercial UAS training and remote ADC, 

mapping, surveying, photography, filming, demonstrations, training, surveying, measuring, and 

inspections of (or for):

1.) Construction, architectural, engineering, insurance, risk management, security, real estate, 

resort, golf, cemetery, entertainment, sports, utility, energy (oil, gas, solar, wind, & electric), 

hydro (water), transportation (port, rail, truck, & bus), mining, bridge, 

telecommunications, agriculture (farming, ranching, & growing) flare stack, platform, tower, 

pole, and pipeline infrastructure, structures, sites, systems, features and operations; and,

2.) Recreational, commercial, governmental, Emergency Management Agencies (EMA) and 

entities; and,

3.) Closed-set motion picture and television (MPT) filming and production which must be 

conducted pursuant to petitioner’s FOM, petitioner’s operating documents, and the MPT 

operations manual (MPTOM) special operating provisions (Appendix AA of petitioner’s FOM); 

and,

4.) Environmental, scientific, conservation, climate change, natural 

resource, wildlife, oceanographic, forestry, weather, search & rescue, emergency 

services, humanitarian relief, public & private entity support, assistance and monitoring 

of infrastructure, structures, sites, systems, features, and operations; and,

5.) Research, education, crew training, development, testing, certification, and validation of 

safe and lawful commercial, hobby, and recreational UAS curriculum, education, and safe flight 

training, demonstrations, and events involving UAS design, manufacture, assembly, purchase, 

sale, maintenance, repair, inspection, safe operation, record keeping, and required FAA 

documentation.

Hereinafter, 1 through 5, above, referred to as petitioner’s "proposed operations".

In support of his application, petitioner confidentially submits his proprietary and confidential 

Flight Operations Manual (FOM), MPTOM, and other manufacturer’s model specific aircraft 

documentation (operating documents) for each aircraft in his fleet of four (4) UAS aircraft (fleet) as 

shown in the table immediately below:

N-Number Serial Number Manufacturer Name

Model

Name

Address
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Each UAS in petitioner’s fleet is in the process of being duly registered with the FAA which will 

assign registration numbers shortly. 

Specific Regulations for which an exemption is sought:

14 CFR 61.113 (a) 

14 CFR 91.7 (a) 

14 CFR 91.119 (b) & (c) 

14 CPR 91. 121

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1)

14 CPR 409 (a) (1) & (2)

14 CFR 417 (a) & (b)

II. PETITIONER’S PROPOSED OPERATIONS DO NOT CREATE SIGNIFICANT HAZARDS

Each of Petitioner’s UAS is an electric multi-rotor craft, weighing less than 55 lbs. including ADC 

payload. Each operates at a speed of no more than 100 mph (87 knots) and has the capability to 

hover, and/or move in a vertical and horizontal plane simultaneously. It will only be operated as 

visual line of sight (VLOS), remain under 400 ft. above ground level (AGL), and will operate only 

over private or controlled access property with permission from the owner/controller of the 

property or authorized representative.

During petitioner’s proposed operations the site will be secured and non-participants will be kept 

at least 500 feet away from the operation unless barriers or structures are present that sufficiently 

protect non-participants in the event of an accident or loss of control.

Petitioner has drafted, and submits confidentially, his Flight Operations Manual (FOM) which 

discusses safety considerations, training, general operating procedures, specifications, inspection, 

maintenance, setup of the UAS, and other proprietary procedures for the proposed UAS 

operations. 

III. PETITIONER'S PROPOSED OPERATIONS ARE IN THE PUBLIC INTEREST

The FAA has issued a Grant of Exemption to FalconSkyCam for operations that are substantially 

similar to those proposed herein. Docket No. FAA-2014-0884 (March 6, 2015). In issuing the Grant, 

the FAA noted that "[t]he enhanced safety and reduced environmental impact achieved using a 

TBD TBD DJI INNOVATIONS

PHANTOM 3 PROFESSIONAL DONNY ROBERT MELARA

TBD TBD DJI INNOVATIONS

S-1000 A2 FLIGHT CONTROL DONNY ROBERT MELARA

TBD TBD DJI INNOVATIONS

INSPIRE 1 DONNY ROBERT MELARA

TBD TBD DJI INNOVATIONS

PHANTOM 2 DONNY ROBERT MELARA
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UAS with the specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable 

fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the 

public interest."

Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption 

summarily and without delay.

IV. EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that each of his UAS with the characteristics and as operated with the 

limitations listed below, provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory framework.

These limitations and conditions to which Petitioner agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

1.) Each UAS utilized by Petitioner will weigh Less than 55 lbs, operate at a speed of no more 

than 100 mph (87 knots), and will remain under 400 ft. (AGL).

2.) Flights will be operated only during daylight hours, only in visual meteorological conditions, 

and only within visual line of sight (VLOS) of the pilot in command (PIC) of the UAS.

3.) All operations will utilize a visual observer (VO) in addition to the pilot in command (PIC).

4.) Maximum total flight time for each operational flight will be approximately 30 minutes, or 

when the Low Battery warning activates.

V. EXEMPTIONS REQUESTED

14 C.F.R. § 61.113 (a) and (b): Private, Recreational, or Sport vs. Commercial Pilot Certificates

Sections 61.113 (a) and (b) prohibit private, recreational, or sport certified pilots from operating a 

traditional aircraft for compensation or hire. Petitioner proposes that his PIC will have at least a 

private, recreational, or sport pilot’s certificate, and a current FAA medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or 

the Federal government. Petitioner’s 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. 

Petitioner will not permit any PIC to operate unless the PIC demonstratesthe ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under petitioner’s 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be 

logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

petitioner’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated under 
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petitioner’s exemption are requested by petitioner to be allowed under the terms of this 

exemption. 

Petitioner further proposes that such PIC and VO training operations will only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations will be considered nonparticipants, and the PIC will 

operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR §

91.119.

Based upon the above and for the reasons set forth in the FAA's grant of an exemption to Astraeus 

Aerial, Petitioner does not believe a commercial pilot certificate is necessary for the operations it 

intends to conduct. See, e.g., In the matter of the petition of Astraeus Aerial, Exemption No. 11062 

(issued Sept. 25, 2014). For those reasons, Petitioner requests an exemption from 14 C.F.R. § 

61.113 (a) and (b).

14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness

Section 91.7 prohibits operation of an unairworthy aircraft, and places responsibility for 

airworthiness determinations on the PIC. The UAS will not have an airworthiness certificate, and 

there is no FAA regulatory standard for determining airworthiness of the UAS. Additionally, 

Petitioner's operating documents, including FOM, set forth inspection and maintenance procedures 

to ensure airworthiness. For these reasons, and in accordance with the FAA's grant of an 

exemption from section 91.7 to Total Safety U.S., Inc., Petitioner requests an exemption from 14 

CFR. § 91.7(a). See, e.g., In the matter of the petition of Total Safety U.S., Inc., Exemption No. 

11156 (issued Jan. 29, 2015).

14 C.F.R. §91.119 (b) and (c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (b) prohibits 

aircraft in congested areas from flying less than 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. To the extent that Petitioner’s proposed operations 

would be considered to be in "congested areas," Petitioner's operational procedures, including 

FOM, and the size, weight and speed of each UAS, provide an equivalent level of safety such that 

the proposed operations at lower altitudes should be allowed.

As described in his Flight Operations Manual (FOM), Petitioner will establish a 500' buffer/sterile 

area for its operations that will exclude personnel not associated with the operations. Petitioner 

will also exercise additional control over the sterile area as needed, as set forth in the FOM. 

Consequently, Petitioner believes these procedures will reduce or eliminate any potential adverse 

impacts to safety for operations in congested areas. Petitioner therefore requests an exemption 

from 14 CFR § 91.119(b).

Section 91.119 (c) prohibits operations in other than congested areas below 500 feet above the 

surface, or closer than 500 feet to any person, vessel, vehicle or structure. Since this exemption is 
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for a UAS that flies similarly to a helicopter and requests authority to operate at altitudes up to 400

ft. AGL, an exemption may be needed to allow such proposed operations.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as 

the location where it is operated. As discussed above, Petitioner’s FOM provides for establishment 

of a sterile area, including safety buffers of 500 feet for personnel not associated with the 

operation. Petitioner therefore requests an exemption from Section 91.119(c) for all authorized 

personnel associated with the proposed operations.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain a cruising altitude by 

reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the UAS may not have a barometric altimeter, but 

instead a constant GPS altitude read out, an exemption is requested.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "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."

Maximum total flight time for each of the proposed operations will be no more than 30 minutes. 

Flights will be safely landed when the battery falls below its nominal voltage, should that occur 

prior to completion of the operation. Petitioner’s UAS has a constant battery voltage display and a 

Low Voltage LED Warning which alerts when the battery reaches pre-determined levels. This 

battery level would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its limited operating area when the Low Voltage Warning alerts.

For these reasons, Petitioner requests an exemption from 14 C.F.R. § 91.151 (a). Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 

10808.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "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 

...," and others shall inspect or maintain the aircraft in compliance with Part 43.

As provided in petitioner’s FOM, the operator and the PIC will ensure that the UAS is in working 

order prior to initiating each flight, and the operator will perform required maintenance and 

inspections, and keep a log of any maintenance performed.
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VI.REGULATIONS FOR WHICH EXEMPTIONS ARE UNNECESSARY

The Federal Aviation Administration (FAA) has issued numerous prior exemptions for many 

different types of UAS operations. In those exemptions, the agency noted that exemptions from 

certain regulations were not necessary, due to "the size, weight, speed and limited operating area 

associated with [the UAS] and its operation."

Based upon the FAA's guidance and the fact that petitioner’s UAS is even smaller and slower than 

many of those UAS in previously issued exemptions, Petitioner believes exemptions from the 

following regulations are not necessary:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates. 

14 C.F.R. § 45.23 (b): Marking of the Aircraft.

14 C.F.R. §91.7(b): Civil aircraft airworthiness. 

14 C.F.R. §91.109: Flight instruction.

Petitioner also believes that an exemption from 14 C.F.R. § 91.103: Preflight Action is not 

necessary. This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. An FAA approved rotorcraft flight manual will not be provided for the 

aircraft. An equivalent level of safety will be provided as set forth in the FOM and operating 

documents submitted as part of this request.

The FAA has previously found that adherence to procedures contained in an applicant's operating 

documents demonstrate compliance with § 91.103, and therefore an exemption from the 

regulation was not necessary. See, e.g., In the matter of the petition of Total Safety U.S., Inc., 

Exemption No. 11156 (issued Jan. 29, 2015).

As detailed in his operating documents, petitioner's PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff clearance distances and aircraft 

performance data before initiation of flight to ensure the safety of the flight. Consequently, in light 

of this agency's prior finding in Total Safety U.S., Inc., Petitioner does not believe an exemption 

from 14 C.F.R. § 91.103 is necessary. 

If it is determined that the petitioner does require exemptions from any of the above provisions 

from which he has herein stated that he believes no exemption is required: Petitioner requests that 

such exemptions be granted upon the basis of all that he has stated in this petition and in his 

operating documents.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:
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14 C.F.R. § 61.113 (a) and (b); 91.7 (a); 91.119 (b) and (c); 91.121; 91.151 (a); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to conduct training and aerial 

data collection (ADC) which includes any remote sensing and measuring by an 

instrument(s) aboard the Unoccupied (Unmanned) Aircraft (UA). Examples include 

imagery (photography, video, infrared, etc.), electronic measurement (precision 

surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or 

any other gathering of data by instruments aboard the UA.

Approval of exemptions allowing commercial operations of UAS for these purposes will 

enhance safety by reducing risk. Conventional means for performing these assessments 

require either physically climbing or scaling structures, poles or towers, using ropes to 

scale or rappel up or down poles, towers or structures, using high-reach man lifts to 

access the towers, poles, sites, or structures (limited reach), or by using conventional 

helicopters or traditional aircraft operating at extremely low altitudes over the subject 

structure, pole, site, or tower being examined. These conventional means all pose high 

risks to persons and property, including many actual human deaths each year.

In contrast, a UAS weighing less than 55 lbs. and powered by batteries, eliminates 

virtually all of that risk given the reduced mass and lack of combustible fuel carried on 

board. The UAS is carried by hand to the proposed operations site and not flown. The 

UAS carries no passengers or crew and, therefore, will not expose them to the risks 

associated with traditional manned aircraft flights; ground based aerial lift (bucket 

truck) operations, or manual climbing, scaling, and inspection operations.

The proposed operations of these small UAS, each weighing less than 55 lbs., conducted 

in the strict conditions outlined in this petition, will provide an equivalent level of safety 

supporting the grant of the exemptions requested, including exempting Petitioner from 

the requirements of Part 21 and allowing commercial UAS operations. These lightweight 

aircraft operate at slow speeds, and close to the ground, and, as a result, are far safer 

than the conventional alternatives.

Privacy

All of the proposed operations, UAS flights, will occur only over private or controlled 

access property with permission from the owner/controller of the property or 

authorized representative. Petitioner’s proposed operations will be conducted in

accordance with all applicable laws and regulations governing privacy at the venue of 

the flight operation.

VII. CONCLUSION

Petitioner, Air Cam Shots, has requested to use two small UAS for training and aerial data collection 

(ADC). The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in this petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket 

No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS 
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Global, LLC (see Docket No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), and 11625 to DART drones, LLC. (see Docket No. FAA–2015–0551), the FAA 

found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications

described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good 

cause to find that the UAS operation enabled by granting an exemption to petitioner is in the public

interest.

Upon review of petitioner’s reasons for requesting these exemptions, It reasonably should be 

determined that:

1.)They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, 11625, and 11213;

2.)The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112,

11625, and 11213 also apply to the situation petitioner presents; and

3.)A grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, Petitioner 

should be granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b), to the extent necessary to allow the petitioner’s proposed operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas and daylight UAS operations to 

within visual line of sight (VLOS) and national security - provide more than adequate justification to 

grant the requested exemptions allowing the proposed operations in the NAS by petitioner, Donny 

Robert Melara dba Air Cam Shots.

Respectfully,

/Signed/

Erick F. Larsen

Consultant to 

Air Cam Shots 

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com