Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Name: Mia Schulman on behalf of Erik Anders Lang of PICTURES, PICTURES. LLC 

Address: 5240 Alhambra Ave., Los Angeles, CA 90032

Email: mia@picturespictures.co

Phone: (858)668-6622

The specific section or sections of 14 CFR from which you seek an exemption

Petition for Exemption under SEC 333.

The extent of relief you seek and the reason you seek the relief

SEC 333 prohibits the use of a UAS for commercial purposes without a permit. 

PICTURES, PICTURES. LLC is petitioning for an exemption, to provide a means for our 

film production company to be able to use our UAS to obtain wide landscape shots for 

the sake of artistry. Aerial shots can positively change the quality of a film; they are 

creative, show a new perspective, and can have an emotional impact. PICTURES, 

PICTURES. LLC would like to be able to accept compensation for delivering the highest 

quality film and television content to our clients, by including brief shots obtained with 

our UAS, therefore making this a commercial use of a UAS.

Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule

Being a production company, we are always held accountable and liable for the safety of 

people in our crew’s vicinity when filming, and therefore we understand the importance 

of adhering to all applicable safety and non-safety rules and laws concerning our filming 

methods. Having a combined experience in the film industry of 35 years, we would be a 

good candidate for exemption of SEC 333 while not putting Air Safety in any accelerated 

risk. The specific UAS we are seeking exemption with is one with safety programs, 

including GPS-enabled Return Home and Position Holding, and System Controls offered 

through an app accessible via smart phones and electronic tablets (the Phantom 3 is often 

used by individuals for recreational/hobby purposes, and is therefore designed very 

simply). When flying for this commercial purpose we would be flying at a maximum 

altitude of 400 feet. Our general knowledge of the aviation safety systems implemented 

by the FAA through our research would be used to ensure that safety would not be 

affected by our operations. We will not be flying near disaster areas, hospitals, prisons, or 

high traffic areas including airports.

How your request would benefit the public as a whole

My request benefits the public as a whole by providing top quality entertainment and 

commercial content for public consumption. The quality of a film, short video, or 

program can vastly improve for the reasons listed in the aforementioned paragraph. 

We intend to follow these suggested safety regulations
• Always keep a safe distance in all directions around your model to avoid collisions or 

injury. 

• Always operate your model in open spaces away from full-size vehicles, traffic and 

people.

• Always carefully follow the directions and warnings for this and any optional support 

equipment (chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach of 

children.

• Always avoid water exposure to all equipment not specifically designed and protected 

for this purpose. 

• Never place any portion of the model in your mouth as it could cause serious injury or 

even death.

• Always keep aircraft in sight and under control.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered. 

• Always remove batteries before disassembly.

• Always keep moving parts clean.

• Always let parts cool after use before touching.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

About the UAS: DJI Phantom 3

The DJI Phantom 3 is a vertical takeoff and landing Unmanned Aircraft System with a 

Ground Control Station, that utilizes electronic tablet or smart phone systems. The DJI 

Phantom 3 has a maximum gross weight of approximately 2.8 lbs., has a diagonal 

dimension of 23.2 inches, a maximum speed of approximately 16.4 feet/second and a 

maximum flight altitude of 400 feet. The DJI Phantom 3 is equipped with four main 

rotors , and is driven by a Lithium Polymer battery which lasts under 25 minutes. 

A summary we can publish in the Federal Register

We, PICTURES, PICTURES. LLC, are seeking an exemption of the FAA’s SEC 333 

rules that does not allow the use of an Unmanned Aircraft System to be used for 

commercial purposes in regards to National Airspace Safety. I am petitioning on behalf 

of Erik Anders Lang of PICTURES, PICTURES. LLC, a film/web/commercial/music 

video production company for an exemption to provide a means for our company to be 

able to use our UAS to obtain wide landscape shots for our art. Being a production 

company composed of veteran filmmakers, and therefore understanding the importance 

of prioritizing safety and its specific regards to each project, including FAA regulated 

airspace when using our UAS, we would be a good candidate for exemption from Section 

333 while not putting Air Safety at risk. The specific UAS (DJI Phantom 3) I am seeking 

exemption with is one with many safety programs, including GPS navigating. When 

flying for this commercial purpose I would be flying at a maximum altitude of 400 feet. 

Our general knowledge of the aviation safety systems implemented by the FAA would be 

used to ensure that safety would not be affected by our operations. We would not be 
flying near disaster areas, stadiums, hospitals, prisons, or high traffic areas including 

airports. I appreciate the FAA’s consideration of this petition for exemption.

If you want to exercise the privileges of your exemption outside the United 

States, you must state the reason

Given the nature of our work, we may be commissioned for a project that specifically 

requires an aerial shot outside the U.S.. Should such a case present itself, we will comply 

with any additional safety laws for that or those countries.