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Center Stage Videos

Attn: Matthew T Wise

7517 Keith Lane

Sachse, TX 75048

July 7, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Update to Exemption No. 13730 Regulatory Docket No. FAA-2015-3926. Included is the original 

exemption that was approved and on page 2 we have added a third type of drone. The DJI Phantom 4 

which provides more safety and stability. No other changes have been made to the previously 

approved document.

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, Center Stage Videos, operator of an Unmanned Aircraft System (UAS), hereby 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. This request for exemption is 

similar, if not identical, to many previously submitted requests that have received exemption.

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

sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use in Real Estate sales.

2. Aerial video and/or photography for public and/or private use including public events, and 

cinematography.

3. Aerial photography of residential/commercial structures under contract with the owners or local

government authority.

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 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.”
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The name and address of the applicant is:

Center Stage Videos

Attn: Matthew T Wise

Ph: 817-490-1599

Email: matt@centerstagevideos.com

Address: 7517 Keith Lane Sachse, TX 75048

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.3

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

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)

Center Stage Videos will operate a three models of sUASs, the DJI Phantom 2 Vision +, the DJI 

Phantom 4 and the Cheerson CX-20. Each sUAS will be powered using lithium polymer batteries and 

controlled with a remote transmitter operating on 2.4Ghz or 5.8Ghz band. The applicant will operate 

the UAS in line of sight within a closed off and predetermined area owned and/operated by the 

property representative.

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

adhere to the Reform 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 requested exemption with minimum delay.

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.

The applicant agrees to adhere to the following limitations and conditions when conducting 

commercial operations under the FAA issued exemption.

1. The UAS will weigh less than 55 lbs.
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2. The UAS will have a maximum operating speed of no more than 50mph.

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

4. The UAS pilot will be a designated Pilot in Command (PIC) and hold at least a Commercial 

Pilot’s Certificate. 

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

Observer (VO).

6. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time whichever occurs first.

7. 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 filming is planned.

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

consisting of all the days’ production activities.

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

10. 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 unless the respective airports will be 

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

pertinent information and approval is given.

11. The operator will obtain verbal and/or written consent of all persons involved with the planned 

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

area.

12. The PIC and VO will have been trained in operation of UAS.

13. The PIC and VO will be able to communicate by voice at all times.

14. 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.

15. 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, 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 UAS 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 and designated area. These safety enhancements provide a greater degree of safety to the 

public and property owners than conventional operations conducted with airworthiness certificates 
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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," "lightsport," "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 the cabin, cockpit or pilot station on which the word “Experimental” can 

be placed. Given the size of the UAS, two-inch lettering will be impossible. 

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 identification 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 or hire. 

Center Stage Videos may achieve an equivalent level of safety as achieved by current Regulations 

because the applicant’s UAS do not carry any pilots, passengers or 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 pilots used by Center Stage Videos possess current ATP Certificates and have more 

than 1 year experience in the operation of sUASs. Center Stage Videos will not utilize pilots with less 

than Commercial Certificates at any time during commercial operations. 

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. 

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. 
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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 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 UAS will have immediate access to it.

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. 

The PIC will review weather, flight battery requirements, and perform a safety check of the area of 

intended flight to ensure the flight can be conducted safely. 

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 requests 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 at 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 feet AGL, the UAS will not be 

operated more than 200 feet 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 

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 filming 

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

Compared to flight operations with aircraft or rotorcraft weighting 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 addition, 

the low-altitude operations of the UAS will ensure 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 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 GPS altitude read out, an exemption 

may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 
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check list 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 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 UAS provides approximately 30 minutes of powered flight. To meet the 30 

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

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 twilight 

VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §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 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 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 flights to 30 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 

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 

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); 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 
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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 will 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.

Additional Information Matthew T Wise has been involved in the building and piloting of remote 

controlled aircraft for more than 5 years. Additionally Mr. Wise holds an ATP and is a 121 Designated 

Examiner for a large regional jet operation. Center Stage Videos second pilot has been involved in the 

building and piloting of remote controlled aircraft for more than 10 years and he also holds an ATP 

certificate and is a Check Airman at the same regional operation. 

Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate

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

applicant’s UAS.

Sincerely,

Matthew T Wise