August	11,	2015

Petition	for	Exemption	Under	Section	333	of	the	FAA	Modernization

and	Reform	Act	and	Part	11.81	of	the	Federal	Aviation	Regulations

Petitioner:

Hawk	City	Productions

Nick	Lindaman,	CEO

511	Iowa	Avenue,	Office	B

Iowa	City,	Iowa	52245

Regarding Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	C.F.R.	Parts	11.81,	

Hawk	City	Productions	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	

to	allow	commercial	operation	of	its	small,	unmanned	aircraft	for	commercial	videography.	All	

operations	shall	be	conducted	in	compliance	with	the	limitations	outlined	by	the	FAA	as	required	by	

Section	333.

1.	Sections	from	which	exemptions	are	sought:

a. 14	CFR	Part	21,	subpart	H

b. 14	CFR Part	91:

a. 91.103(b)(2)

b. 91.105	

c. 91.109

d. 91.119

e. 91.121

f. 91.151

g. 91.405

h. 91.407

i. 91.409

j. 91.417

2.	Relief	Sought:

1. Hawk	City	Productions	wishes	to	operate	small	Unmanned	Aircraft	Systems	for	the	purpose	

of	producing	commercial	videography	and	documentary	filmmaking.

2. This	exemption	will	cover	the	use	of	the	DJI	Phantom	2	airframe

3. (see	http://www.dji.com/product/phantom-2)
August	11,	2015

3.Public	Benefit:

a. The	use	of	small	Unmanned	Aircraft	Systems	will	allow	Hawk	City	Productions	to	

capture	aerial	videography	at	a	reduced	environmental	impact	compared	to	the	

manned	aircraft	we	traditionally	use.

b. Footage	captured	will	be	used	in	documentary	filmmaking,	serving	to	educate	the	

public	on	historical	and	architectural	landmarks	of	our	community	and	the	state	of	

Iowa.

c. Cost	compared	to	traditional	methods	is	low,	opening	up	the	market	for	more	

consumers	to have	access	to	aerial	videography.

4.	Safety	not	adversely	affected:	

a. Aircraft	will	be	registered	and	marked	in	accordance	with	Section	44711	and	Part	

47	and	Part	45, Subpart	C.	

b. Aircraft	will	comply	with	maintenance	and	inspection	requirements	of	the	

manufacturer.	All	repair	and	maintenance	work	will	be	conducted	or	approved	by	

qualified	personnel and	will	require	a	test	flight	after	such	work.	Records	of	all	

maintenance	and	repair	work	will	be	kept	in	a	maintenance	log	for	each	aircraft.

c. All	flight	operations	will	be	conducted	by	at	least	two	individuals	(PIC	and	observer)	

who	will	maintain	verbal	communication	capability	with	each	other	at	all	times	

during	the	flight,	and	who	will	remain	stationary	on	the	ground	during	the	flight	

operations:

1. A	Pilot	In	Command	(PIC)	who	possess	the	following	credentials:

a. An	Airman	Certificate	issued	under	14	CFR	61	(private	pilot	license)	

screened	by	the	TSA

b. A	Third	Class	medical	certificate	issued	under	14	CFR	67.

c. A	bi-annual	flight	review	under	14	CFR	61.56	

d. Successful	completion	of	a	UAS	knowledge	test	in	a	specified	form.

e. At	least	200	cycles	and	25	hours	of	flight	experience	in	a	UAS	rotorcraft	

(or	UAS	fixed-wing	in	the	case	of	fixed-wing	flight	operations	under	this	

exemption).	Such	cycles	and	hours	may	be	gained	during	flights	under	

this	exemption	if	a	safe	distance	is	maintained	from	persons	in	

accordance	with	14	CFR	91.119.

f. At	least	5	hours	of	flight	experience	and	3	takeoffs	and	landings	in	make	

and	model	being	flown	in	the	prior	90	days.	Such	cycles	and	hours	may	

be	gained	during	flights	under	this	exemption	if	a	safe	distance	is	

maintained	from	persons	in	accordance	with	14	CFR	91.119.
August	11,	2015

2. A	Visual	Observer.

3. A	Sensor	Operator	as	necessary.	

d. All	flight	operations	will	be	conducted	in	accordance	with	valid	Certificates	of	Authorization.

e. All	flight	operations	will	comply	with	the	following:	

a. The	manufacturers’	user	manuals.

b. Information	made	available	by	the	FAA	and	other	resources	including	(but	not	

limited	to)	http://www.knowbeforeyoufly.org and	www.modelaircraft.org as	well	

as	having	Hawk	City	Productions	own	guidelines	on	hands-free	communication,	

maintaining	line	of	sight, battery	monitoring	and	maintenance, and	emergency	

landing/recovery	procedures.

c. Conducted	in	VMC	conditions	during	daylight	hours.

d. PIC	and	VO	will	maintain	VLOS	at	all	times.

e. Pre-flight	inspections	(including	ground	control	station,	if	any)	and	safety	risk	

assessments	will	be	conducted	prior	to	each	flight.

f. Flight	altitudes	will	remain	below	400	feet	above	ground	level.	

g. Flight	ground	speeds	will	not	exceed	50	knots.	

h. Not	intrude	into	Class	B,	C	or	D	airspace,	or	published	approach,	SID	or	STAR,	or	

take	place	within	5	nautical	miles	of	an	airport.

i. Not	be	made	near	persons	as	required	in	14	CFR	91.119	and	not	over	persons	on	the	

ground	without	their	prior	permission.

j. Each	flight	will	be	logged	in	both	the	PIC’s	logbook	and	the	aircraft	logbook.

k. Not	exceed	75%	of	the	battery	or	fuel	capacity	of	the	aircraft,	or	30	minutes,	

whichever	occurs	first.

l. Any	incidents	will	be	reported within	24	hours	of	occurrence.

m. Any	applicable	local	FSDO	requirements.

n. All	other	applicable	regulations	concerned	with	the	operation	of	aircraft.

f. Aircraft	will	use	FCC	compliant	2.4	GHz	for	command	&	control	of	the	aircraft	with	welldefined	and tested	lost	link	procedures.

Sincerely,

Nick	Lindaman

CEO,	Hawk	City	Productions
August	11,	2015