NuttyNu Aerial Videography

Nu Xiong

705 Muldoon Road #49

Anchorage,Alaska 99504

February 10, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 

61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & 

(b).

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, NUTTYNU AERIAL VIDEOGRAPHY (“the applicant”), 

developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to 

conduct aerial cinematography, videography, photography for inspections, and other 

aerial data collection services for the sports, real estate, music, and commercial, 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.

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, 3) controlled as to access, and 4) would 

provide safety enhancements to the already safe operations in the infrastructure and 

business operations industry presently using conventional aircraft. Approval of this 

exemption 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.” Section 333(c) of the Reform 

Act.

The name and address of the applicant is:

NUTTYNU AERIAL VIDEOGRAPHY
Attn: Nu Xiong

Ph: 907-444-5524

Email: Nuttynurider@gmail.com

Address: 705 Muldoon Road #49 Anchorage, Alaska 99504

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.10314 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rule making required 

under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS or 

the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate 

safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis 

added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, which includes sUASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 

USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

The applicant’s sUAS (Appendix 1) are fixed wing and rotorcraft, weighing 55 or fewer 

lbs. including payload. They operate under normal conditions at a speed of no more than 

10 to 20 knots and have the capability to hover and move in the vertical and horizontal 

plane simultaneously and move in the horizontal plane. They will operate only in line of 

sight and will operate only within the sterile area described in the Unmanned Aircraft 

Systems Operations Manual, attached as Appendix 2 (hereinafter “the Manual”). Such 

operations insure that the sUAS does “not create a hazard to users of the national airspace 

system or the public.”

Given the small size of the sUASs involved and the restricted sterile environment within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also due to 

the size of the UASs and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for aerial 

cinematography, videography, photography for inspections, and other aerial data 

collection services for the sports, real estate, music, and commercial, the granting of the 

requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay.

Background Information

The applicant is in the business of aerial cinematography, videography, photography. The 

applicant’s clients look to the applicant for safe operations of sUAS. The applicant has 

developed specific safe UAV operational procedures. Increasingly, the applicant has 

clients looking for sUAS services for aerial cinematography, videography, photography 

for inspections, and other aerial data collection services for the sports, real estate, music, 

and commercial.

Operations performed by the applicant include:

Cinematography

Videography

Photography

Utility Inspection
Railroad Inspection

Pipeline Inspection

Land Development

Real Estate 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe aerial videography and photography conducted with 

conventional aircraft.

These limitations and conditions to which the applicant agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

• The sUAS will weigh less than 55 lbs.

• Flights will be operated within line of sight of a pilot and/or observer.

• Maximum total 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.

• Flights will be operated at an altitude of no more than 400 feet AGL or, not more 

than 200 feet above an elevated platform from which flight is planned.

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer.

• The sUAS pilot-in-command (PIC) will hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will also hold 

a current FAA airman 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

• If a pilot certificate holder other than the sUAS Pilot, who possess the necessary 

PIC qualifications, is also present on site, that person can also be designated as 

PIC.

• The sUAS will only operate within defined boundaries as outlined in Section 8.4 

of the Manual.

• A briefing will be conducted in regard to the planned sUAS operations prior to 

each mission. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing.

• The operator will file a FAA Form 7711-1, or its equivalent, as modified in light 

of the requested exemption, with the appropriate Flight Standards District Office 

(FSDO).

• The operator will obtain the consent of all persons involved in the mission and 

ensure that only consenting persons will be allowed within 100 feet of the flight 
operation, and this radius may be reduced to 30 feet based upon an equivalent 

level of safety determination, as required by Section 8.4 of the Manual. With the 

advanced permission of the relevant FSDO, operations at closer range can be 

approved.

• The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed mission as required in Section 8.1 of the Manual. Items will 

include:

• Dates and times for all flights;

• Name and phone number of the operator for the UAS mission conducted 

under this petition of exemption;

• Make, model, and serial or N-number of UAS to be used;

• Name and certificate number of UAS PICs involved in the mission;

• A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the mission;

• The list of those who gave permission made available to the inspector 

upon request;

• Signature of exemption-holder or representative; and

• A description of the flight activity, including maps or diagrams of any 

area, city, town, county, and/or state over which the mission will be 

conducted and the altitudes essential to accomplish the operation.

• Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as required 

in Sections 7.4 and 7.5 of the Manual.

• Observer and pilot will at all times be able to communicate by voice.

• Written and/or oral permission from the relevant property holders will be 

obtained.

• All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.

• If the sUAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and 

land.

• The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles 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, establishes 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 H meets the requirements of an equivalent 

level of safety under Part 11 and Section 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, an analysis of these 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 certificate without the 

restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and observer, pursuant to the Manual’s policies, and under and in compliance 

with local public safety requirements, to provide security for the area of operation as is 

now done with conventional aerial cinematography, videography, photography for 

inspections, and other aerial data collection services for the sports, real estate, music, and 

commercial. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with aerial 

cinematography, videography, photography, provide a 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 operation, 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," "light-sport," "experimental," or 

"provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the 

word “Experimental” can be placed. Given the size of the sUAV, two-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 sUAV marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 
sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a pilot’s certificate operate this small UAS. Unlike a conventional aircraft that 

carries the pilot and passengers, the sUAS is remotely controlled with no living thing on 

board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Manual. The level of safety provided by the 

requirements included in the Manual exceeds that provided by a single individual holding 

a commercial pilot’s certificate operating a conventional aircraft. The risks associated 

with the operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of 

the sUAS as requested by a pilot’s certificate as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b).

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

The regulation requires 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 and the requirements contained in the Manual 

for maintenance and use of safety checklists prior to each flight, as set forth in Sections 

9.1 and 9.6, 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 ... (2) 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 sUAS, 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 pilot 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 sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each 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. An equivalent level of safety will 

be provided as set forth in Sections 8 and 9 of the Manual. The PIC will take all actions 

including 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.

sUASs 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. See Exemption Nos. 5778K & 

9862A. 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 sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which operation is planned, an exemption may be 

needed to allow such operations. As set forth herein, except for the limited conditions 

stated in the Manual, the UAS will never operate at higher than 400 AGL. It will, 

however, be operated in a restricted area with a 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, and speed of the 

UAS as well as the location 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 mission, all affected individuals will be aware of 

the planned flight operations as set forth in Section 6.2, 8.1, and 8.2 of the Manual. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL in the aerial cinematography, videography, photography 

for inspections, and other aerial data collection services for the sports, real estate, music, 

and commercial. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small 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 

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

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual 

and safety checklist, 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 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.”

The battery powering the sUAS provides approximately 30 minutes of powered flight. To 

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 20 minutes 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 night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 

controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, limiting sUAS flights to 20 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 flights to 

20 minutes or 25% of battery power whichever happens first. This restriction would be 

more than adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808.

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 following:

(1) An 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 sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (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.

Given that these sections 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 as 

referenced in the Manual (See Sections 8.6 and 9). An equivalent level of safety will be 
achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

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

feet AGL. As provided in the Manual, 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.

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:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 

(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 

91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to 

operate commercially a small unmanned vehicle (55lbs or less) in motion picture 

and television operations.

Approval of exemptions allowing commercial operations of sUASs in the aerial 

cinematography, videography, and photography will enhance safety by reducing risk. 

Conventional videography and photography, using jet or piston power aircraft, operate at 

extremely low altitudes just feet from the infrastructure being inspected and in extreme 

proximity to people and structures; and present the risks associated with vehicles that 

weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. 

Such aircraft must fly to and from the work location. In contrast, a sUAS weighing fewer 

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 sUAS is carried to the 

worksite and not flown. The sUAS will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s 
prior consent and knowledge. Aerial videography & photography will be performed for 

people who have also consented for work to be performed or otherwise have agreed to be 

in the area where UAS flight will take place. 

Conclusion

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 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s UAS in the Aerial videography & photography pursuant to the Manual 

appended hereto.

Sincerely,

Nu Xiong

Owner

NuttyNu Aerial Videography

Appendix 1

1.1 – DJI Phantom 3 Professional
See Attached Flight Manuals: 

sUAS Product Owners Manual 

Appendix 2

Please see the attached:

NuttyNu Aerial Videography sUAS Operating Manual

NuttyNu Aerial Videography sUAS Pre-Flight Safety Checklist