Pilot Productions, LLC

Owner, Mason Dunn

704 NW 16th St.

Moore, OK 73160

Dear Sir or Madam:

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

CFR Part 11, Mason J. Dunn, operator of an Unmanned Aircraft System (UAS), herby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”), to allow commercial operation of its 

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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner: 

 Providing live video feed to assist with search and rescue operations including, but not limited 

to, emergencies or national disasters, only when the local authorities/government has 

requested it by contract or donation

 Photography/Videography

 Cinematography

 Real estate

 Architecture

 Land surveying/mapping/engineering/architecture and other related professional activities

 Photography/videography of golf course activities 

 Field inspections for structures and infrastructures

 Television

 News gathering/live video feed

 Motion pictures

 Pipeline inspections

 Inspection of residential/commercial utility infrastructure, including, but not limited to, 

electrical powerlines/right-a-way, wind turbines, and cell towers

 Construction sites

 Roof inspections

 Solar inspections

 Public and private events

 Insurance claims

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for 

the protection of the persons and property. 

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using conventional 

aircraft. Approval of this exemptions would thereby enhance safety and fulfill the Secretary of 
Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the National Airspace System.”

Regulations from which the exemptions are requested:

14 CFR Part 21 Subpart H

14 CFR 45.23 (B)

14 CFR 61.113 (A) (B)

14 CFR 91.7 (A)

14 CFR 91.9 (B) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (C)

14 CFR 91.121

14 CFR 91.151 (A)

14 CFR 91.203 (A) (B)

14 CFR 91.405 (A)

14 CFR 91.407 (A) (1)

14 CFR 91.409 (A) (2)

14 CFR 91.417 (A) (B)

Pilot Productions, LLC, will operate the DJI Phantom 3 Pro, DJI Inspire 1

The DJI Phantom 3 Pro has a total weight of 1280g or 2 lbs. 13 oz. The dimensions are 40.36cm x 40.36 x 

19.05cm or 16 inch x 16 inch x 7.5 inch. Under still air the maximum speed is no more than 16m/s or 35 

mph with a cruising speed of 11m/s or 25 mph. The DJI Phantom 3 Pro has the ability to hover and move 

along a vertical and horizontal plane simultaneously. The DJI Phantom 3 Pro has four motors, Motor 

Model # DJI 3510, powered by a 4480mAh 4s LiPo Lithium Polymer battery. There are four propellers, 

Propeller Model # DJI 1345, in use. The DJI Phantom 3 Pro will be controlled with the C3 remote 

controller with an operation frequency of 2.4GHz – 2.483GHz. The live video feed will have an operating 

frequency of 2.4GHz ISM with maximum range of 1.2 miles. The applicant will operate the UAS in line of 

sight within a closed off and predetermined area owned and/or operated by the property 

representative. 

DJI Phantom 3 Pro

General Features

 Ready to fly

 3 axis camera stabilization

 Precision flight and stable hovering

 GPS positioning & auto return home

 Onscreen real-time flight parameters

 High Definition 4k Camera

 Camera tilt control

 Film straight down

 Supports Adobe DNG RAW

 Adobe lens profile support

 Camera parameter settings

 Album synchronization

 FAA no-fly zones locked out via installed software

Transmitter
 Operating Frequency: 2.400 GHz – 2.483 GHz

 Communication distance (open area) :CE: 2000m; FCC 2000m

 Receiver sensitivity (1%PER): -101dBm +/- 2dBm

 Transmitter power: CE: 16dBm; FCC: 20dBm

 Working voltage: 1.2A @ 7.4V

 Battery: 6000 mAh LiPo 2s

Camera

 Operating Environment Temperature: 0C-40C

 Max resolution: 4096 x 2162p @ 24/25fps

 FOV: 94/85

 Sensor size: 1/2.3”

 HD recording: 4k p 24/25fps/720p 60fps

DJI Vision APP

 System Requirement of Mobile Device: IOS version 6.0 or above/Android system version 4.0 or 

above

 Mobile device Support: Recommended: Ipad Air2, Ipad mini, iphone4s, iphone5, iphone5s, ipod

touch4, ipod touch5, iphone6

Pilot Productions will also operate a DJI Inspire 1 with a total weight of 2935g or 6 lbs. 47 oz. The 

dimensions are 438 x 451 x 301mm or 17.24 x 17.75 x 11.85”. Under still air the maximum speed is 

no more than 22m/s or 50 mph. The DJI Inspire 1 has the ability to hover and move along a vertical 

and horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Model # DJI 3510H.

There are four propellers, Propeller Model # DJI 1345T and is powered by a 22.8 V with 5700 mAh

Intelligent Flight Battery {TB48}. The DJI Inspire 1 will be controlled with the C1 remote controller

with an operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an operating 

frequency of 2.4GHz ISM with maximum range of 1.2 miles. The applicant will operate the UAS in 

line of sight.

DJI Inspire 1

 General Feature

 Ready to fly

 3-axis camera stabilization

 Precision flight and stable hovering

 GPS positioning & auto return home

 Onscreen real time flight parameters

 High definition 4K camera

 Camera tilt control

 Film straight down

 Supports Adobe DNG RAW

 Adobe lens profile support

 Camera parameter settings

 Album Synchronization

 FAA no-fly zones installed 

Transmitter

 Operating Frequency: 2.400GHz – 2.483GHz

 Communication Distance: 2000m; Fcc 2000m
 Receiver sensitivity: 1% - 101dBm +/- 2dBm

 Transmitter power: CE 16dBm: FCC 20 dBm

 Working voltage: 22.8V

Camera

 Operating Environmental Temperature: 0 degrees – 40 degrees C

 Resolution: 12.0MP

 FOV: 94 degrees

 Sensor size: 1//2.3’

 HD recording 4K 4096 x 2160P

DJI Vision APP

 System requirement of mobile device: IOS version 6.0 or above/Android system version 4.0 or 

above

 Mobile device support: Recommended: Ipad air2, Ipad mini, iphone4s, iphone5, iphone5s, 

iphone6. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set fourth in the flight operations manual 

(FOM) include:

 The UAS will weigh less than 55 lbs. (DJI Phantom 3 Pro weighs 1280G or 2 lbs. 13 oz./DJI 

Inspire #1 weighs 2935 grams or 6 lbs. 47 oz.)

 The UAS will have a maximum operation speed of no more than 50 mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC), and/or Visual 

Observer (VO).

 Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 

25% battery power reserve or 20 minutes of flight time, whichever comes first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL), and 

not more than 200 feet above an elevated platform from which filing is planned. 

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO), and 

may include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC), and will take and pass all necessary 

certifications currently being approved by the FAA administration for commercial use.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight 

consisting of all the day’s production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC), only.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP), of a tower controlled or uncontrolled airport. The DJI Phantom 3 Pro and the DJI 

Inspire 1, has a built in software for all FAA regulated “No Fly Zones”, and was uploaded by DJI 

(Feb 2015), for all DJI drones to download and prevent any possible flights occurring within nofly zones. 

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point 

(APR), of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight and other 

pertinent information. 
 The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local flight Standards District Office (FSDO), no more than 72 

hours but no less than 48 hours from planned operation. 

 The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 100 feet of the flight

operations, and the radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required under the FOM. With the advanced permission of the FSDO, 

operations at closer range may be approved. 

 The PIC and VO will have been trained in operation of UAS and receive up-to-date information 

for the particular UAS to be operated. 

 The POC and VO will be able to communicate by voice, radios, and/or text at all times. 

 Written and/or verbal permission and permits will be obtained from territorial, state, county or 

city jurisdictions, including law enforcement, fire or other appropriate government agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will 

have the capability to return to a pre-determined location within a designated location and land 

autonomously.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, established the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (A) (1). Given the size and limited operating 

area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart 333 

of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (F), and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS. In all cases, and analysis of the criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft), operating with an 

airworthiness certificated without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs., carries neither a pilot nor passenger, carries no 

explosives materials or flammable liquid fuels, and operates exclusively within a secured and designated 

area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator and under the requirements and in compliance with local public safety 

requirements. These safety enhancements provide greater degree of safety to the public and property 

owners than conventional operations, conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operations, location of operation, 

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

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

The regulation requires:

When marks include only the roman capital letter “N”, and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters, not less than 2 inches nor more than 6 inches high, the words “limited”, “restricted”, “lightsport”, “experimental”, or “provisional”, as applicable. Even though the UAS will have no airworthiness 

certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the “Experimental” can be placed. Given the size of the UAS, 2-inch lettering will be 
impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (F). The 

equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (F), where the pilot, observer, and others working with the UAS will see the identifications of the 

UAS as “Experimental”. 

14 C.F.R. §61.113 (A) and (B): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (A) & (B), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation for hire. An equivalent 

level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any 

pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk 

levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth 

in the FOM will equate to the safe operation of the UAS. 

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

The regulations require that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. §91.9 (B) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (B) (2), provides: No person may operate a U.S. registered civil aircraft- For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no on board, but 

because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety

will be maintained by keeping the flight manual at the ground control point where the pilot flying the 

UAS will have immediate access to it. 

14 C.F.R. §91.103: Preflight Action.

This regulation requires watch pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved Rotorcraft Flight Manuals will not be provided for the aircraft, an exemption 

will be needed. This PIC will take all actions as stated in the manufacture FOM in the pre-flight 

inspection sections, including but not limited to reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight. 

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

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon), that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, and by 

the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (D), allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption request authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, the UAS will never operate higher than 400 
AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure 

whose height exceeds 400 ft. AGL, the UAS will not be operated more than 200 ft. above the highest 

point on the structure. It will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained consent. The 

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

locations where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighing more than the maximum 55 lbs. Proposed herein and the 

lack of flammable fuel risk associated with these operations is far less than those presently presented 

with conventional aircraft to operating at or below 500 AGL. In addition, the low-altitude operations of 

the UAS will ensue separation between these UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R §91.121 Altimeter Settings.

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

an altimeter that is set “to the elevation of the departing airport or an appropriate altimeter setting 

available before departure”. As the UAS may not have a barometric altimeter, but instead a GPS altitude 

readout, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety checklist and live flight data monitoring, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight.

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 

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”. 

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minute 

in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR 

conditions is reasonable.

Applicant believes that an exemption from 14 CRF §91.151 (A), falls within the scope of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waiver will be allowed, with less than 30 minutes of reserve 

fuel, doesn’t not engender the type of risks that Section 91.151 (A) was intended to alleviate given the 

size and speed for the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce 

the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety 

can be achieved by limiting flight to 20 minutes or 25% of battery power, whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from anywhere 

in its limited operating area.

14 C.F.R. §91.203 (A) and (B): Carrying Civil Aircraft Certification and registration.

The regulation provides in pertinent part:

(A) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the

appropriate and current airworthiness certificate.

(B) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(A) of this section or a special flight authorization issued under §91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no 

more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place 

to carry certification and registration documents or to display them on the UAS. An equivalent 
level of safety will be achieved by keeping these documents at the ground control point where

the pilot flying the UAS will have immediate access to them, to the extent they are applicable to 

the UAS. 

14 C.F.R. §91.405 (A) (1), 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. Given that these section and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in 

size and carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS Manufacturer’s User’s 

Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed. 

Given the small size of the UAS and the controlled environment provided the proposed 

operations will adhere to the Reforms Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed operations 

and the public benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the 

applicant requests that the FAA grant the request exemption with minimum delay.

Thank you for your consideration, 

Pilot Productions, L.L.C.

Owner, Mason J. Dunn

704 NW 16th St.

Moore, OK 73160

405-919-7230

Mason3866@yahoo.com