To the Federal Aviation Authority (FAA),

360 Productions, LLC hereby request exemption from part 21, subpart H; and Sections 45.23(b), 

61.113(a) and (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), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR). 

I support my request with the following information: 

360 Productions, LLC (360P) plans to operate two UAS, the DJI Phantom 2 and the DJI Inspire I. Both are 

comprised of an unmanned aircraft and a transportable ground station. 

The DJI Phantom 2 is referred to as a quad-copter with a maximum gross weight of about 1.3 kilograms. 

It is equipped with four rotors that are driven by electric motors powered by a battery. The UA has a 

maximum airspeed of 15 m/s. The quad utilizes a GoPro hookup

The Inspire 1 is referred to as a quad-copter with a maximum gross weight of about 3 kilograms. It is 

equipped with four rotors that are driven by electric motors powered by a battery. The UA has a 

maximum airspeed of 22 m/s. The quad has a built in high definition camera. 

360 Productions, LLC is a media and content production company based out of Portland, Maine. 360P 

offers clients comprehensive video production services and produces television shows, commercials, 

and online and social media content. 

360P plans to operate the UAs at videography shoots throughout the United States to enhance 

television productions and media quality. I make the following representations of operational 

enhancements which I propose to abide by to ensure this exemption will provide a level of safety at 

least equal to existing rules: 

• I will only operate in reasonably safe environments that are strictly controlled, are away from power 

lines, elevated lights, airports and actively populated areas; and 

• I will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance. 

I state that given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and 

(b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 

(Section 333). 

I request an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, I state that two-inch 

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. Regardless of this, I state that I will mark his UAS in the largest possible lettering by placing 

the word “Experimental” on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a 

spotter will see the markings. 

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 
an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight 

inspection of his UAS before each flight as outlined in my operating documents. 

UAS Pilot in Command (PIC) 

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry any pilots or passengers. Further, I state that, while helpful, a pilot license will not ensure remote 

control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk levels 

inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption 

from § 61.113 Private Pilot Privileges and Limitations: Pilot in command. 

Regarding UAS operational training, I state I have flown numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of 

his UAs’ performance under different temperature and weather conditions. I further state that the 

practices computerized simulated flights to maintain adequate skills and response reflex time.

In a supplemental request to the FAA, I request consideration of a 120 day temporary airman certificate 

in accordance with § 63.13, to allow time to obtain a private pilot certificate or to allow the FAA time to 

establish minimum UAS airman certification standards. 

UAS Operating Parameters I will abide by the following additional operating conditions under this 

exemption:

• operate my UAS below 300 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation; 1 

• operate the UAS for 3-7 minutes per flight;

• land my UAS prior to the manufacturer’s recommended minimum level of battery power; 

• operate my UAS only within visual line of sight (VLOS); 

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost; 

• conduct all operations under my own personal and flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the 

operating documents and will actively analyze flight data and other sources of information to constantly 

update and enhance my safety protocols;

• contact respective airports if operations will be within 5 miles to advise them of my estimated flight 

time, flight duration, elevation of flight and other pertinent information; 

• always obtain all necessary permissions prior to operation; and 

• have procedures in place to abort flights in the event of safety breaches or potential danger. 
I state that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert 

that since there is currently no certificate applicable to my operation, this regulation is inapplicable.

I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no 

pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. 

I further indicate an equivalent level of safety will be achieved by maintaining a safety/flight manual 

with the UAS ground station. I state that § 91.119 prescribes safe altitudes for the operation of civil 

aircraft, but that it allows helicopters to be operated at lower altitudes in certain conditions. I state that 

I will not operate his UAS above the altitude of 300 feet above ground level (AGL) and will also only 

operate in safe areas away from the public and traffic, thus “providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. I assert that given the size, weight, 

maneuverability, and speed of my UAS, an equivalent or higher level of safety will be achieved. 

I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS with a 

barometric sensor.

Public Interest 

I state that aerial videography and photography for brands, events, and television has been around for a 

long time through manned fixed wing aircraft and helicopters, but for small business owners, its 

expense has been cost-prohibitive. Granting this exemption to 360P would allow our company to 

provide this service at a much lower cost. 

Further, I would like to indicate my small UAS will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft. I would also like to state that the 

operation of my UAS will minimize ecological damage and promote economic growth by providing 

information to companies or individuals looking to relocate or build in the Southern Maine region.

(end of petition)

I would like to conclude my petition by sincerely thanking the FAA for their consideration and for taking 

the time to look at 360 Productions petition. Videography is our passion and our work, and something 

we have grown from a small business in Maine to all across the United States and world. We are always 

looking to stay on the forefront of new videography techniques and believe there is a wonderful 

opportunity with these safe, reliable UAs that will only allow us to further provide a masterwork product 

to our clients. Thank you again and I look forward to hearing from you in the near future

Best,

Parker Swenson

Productions Manager, 360 Productions (www.360mediaventures.com)

28 Danforth St, Suite 210 Portland ME 04101

pswenson@360mediaventures.com

207-699-2360 x105