Willis Chung

Sclera Digital, Inc.

1100 Wilshire Blvd., #1803

Los Angeles, CA 90017

(818) 835-3128

willisxchung@gmail.com

Petition for Exemption

Federal Aviation Administration

Re: Unmanned Aircraft System use in NAS for compensation

Petitioner, Sclera Digital, Inc. (“Sclera”), hereby petitions the Federal Aviation 

Administration (“FAA”) for an exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 

91.9(b)(2); 91.103; 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). The proposed exemption, if granted, would allow operation of unmanned aircraft systems 

(UAS) for the purpose of closed-set filming for the motion picture and television industry.

The terms and conditions of Grant of Exemption No. 11062 (Petition of Astraeus Aerial, 

Regulatory Docket No. FAA-2014-0352) are hereby incorporated by this reference as if fully set 

for herein with the exception of the mandatory Class 3 medical certificate.

Petitioner hereby proposes the following terms and conditions for the grant of the 

exemption requested herein:

The UAS proposed by the petitioner, the Inspire 1 is an unmanned four-rotor, four-motor 

“quadcopter” manufactured by DJI. The UAS is under 45pounds, will be flown at all times 

under 300 feet AGL as measured by the UAS’ on-board GPS system, will be kept within line of 

sight of the Pilot in Command (“PIC”), will have a separate safety Visual Observer (“VO”) at all 

times in communication with and within 5 feet of the PIC, will be flown at all times at speeds of 

40 miles per hour or less, will be flown at all times during daylight hours, always using Visual 

Flight Rules (“VFR”) and within visual line of sight (“VLOS”), and never using first person 

view by the PIC. The PIC will be able to use human vision unaided by any device other than 

corrective lenses as specified by a current state-issued driver’s license. The PIC will provide the 

local Flight Standards District Office (“FSDO”) with notice of all of flight operations no less 

than 72 hours in advance of any intended flight. Each PIC will have over 400 hours of logged 

flight experience in the same UAS type or model, including 10 take offs and landings within the 

prior 30 days. The PIC will conduct a full and complete inspection of aircraft prior to the initial 

takeoff of each flight.

Public Benefit
Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 

500 feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL and in 

fact the best video quality is 50 to 100 feet. A large manned helicopter could also cause very

serious damage to persons or property on the ground and even to pilots and passengers inside a 

manned helicopter. A UAS weighing in at approximately six pounds would not be nearly as 

hazardous. Additionally, a regular helicopter is normally larger than a standard automobile 

whereas the UAS is smaller than a basketball. It is substantially safer for the public to have a 

UAS accomplish the job of aerial photography than a manned helicopter just based on size alone.

In addition, the UAS can be operated for substantially less costs than a regular manned 

helicopter. The public is significantly served by reducing the cost of videography via UAS 

aircraft.

Proposed Operational Parameters

The PIC will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will

be established and identified in the operator’s manual. At a minimum, the following will be 

included in the operator’s manual: 

1. Actuators / Servos 

2. Transmission (single rotor) 

3. Powerplant (motors) 

4. Propellers 

5. Electronic speed controller 

6. Batteries 

7. Mechanical dynamic components (single rotor) 

8. Remote command and control 

9. Ground control station (if used) 

10. Any other components as determined by the operator 

Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

will be prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be 

included in the preflight inspection. All maintenance and alterations will be properly documented 

in the aircraft records. 

Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics (e.g. replacement of a flight critical component) will undergo a functional 

test flight in accordance with the operator’s manual. The PIC who conducts the functional test 

flight will make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to the operator’s 

manual. 
Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of five hours as a UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight time and 

90 day currency. During training, proficiency, experience-building, and take-off and landing 

currency flights all persons not essential for flight operations are considered non-participants, 

and the PIC must operate the UA with appropriate distance from non-participants in accordance 

with 14 CFR § 91.119. 

Prior to any flight operations authorized by this grant of exemption, the PIC and VO must 

have successfully completed a qualification process, as outlined in the operator’s manual. As this 

is a requirement stipulated by the operator, the test must be developed and implemented by a 

qualified person designated at the sole discretion of the operator. A record of completion of this 

qualification process must be documented and made available to the Administrator of the FAA

(the “Administrator”) upon request. 

Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical test 

standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual. 

The UAS will not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface in 

the event of a UAS failure or emergency. 

Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons must 

be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (“ASI”) approval is 

necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent 

with the manned aircraft procedures described in FAA Order 8900.1, Volume 3, Chapter 8, 

Section 1 Issue a Certificate of Waiver for Motion Picture and Television Filming (the “Order”).

Regarding distance from non-participating persons, the operator will ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet if it 

would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the 

filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such 
barriers may protect non-participating persons (e.g. observers, the public, news media) from 

debris in the event of an accident. This is also consistent with the Order. 

If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the operator’s manual. The proposed UAS, the DJI Inspire 1, is designed to increase altitude 20 

meters or 60 feet upon loss of signal between the ground controller held by the pilot and the 

aircraft itself. Upon reaching the higher altitude (a safety feature to avoid people, trees and 

buildings), the UAS will return to its original take-off point of origin and slowly land. It is 

critically important for the pilot to calibrate the aircraft prior to its flight. The calibration 

procedure sets the compass and lets the aircrafts onboard computer know where it is located on 

Earth. The UAS also has a Flytrex black box system installed which tracks every flight so if a 

loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve 

the UAS when it lands. Additional details concerning lost-link failsafes can be found in the 

Operator’s Manual.

The PIC will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

Each UAS operation must be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 

The PIC will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 

48 hours prior to the operation.

The operator will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures will be added to the operator’s 

manual. 

Each UAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual. 

Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (“FCC”) or 

other appropriate government oversight agency requirements. 
At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the UAS filming production conducted under 

this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation of the UAS 

d. Make, model, and serial or N-number of UAS to be used 

e. Name and certificate number of UAS PICs involved in the filming production event 

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must be 

made available to the inspector upon request. 

g. Signature of exemption-holder or representative 

The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PIC at the 

ground control station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (“VMC”). Flights under 

special visual flight rules (“SVFR”) are not authorized. 

The UAS will be operated by the PIC from any moving device or vehicle. 

The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 

The UA will not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA will not operate within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 
Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA UAS Integration Office (AFS-80) within 24 hours. Such accidents must be reported to the 

National Transportation Safety Board (“NTSB”) per instructions contained on the NTSB Web 

site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, 

or transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

Unless otherwise specified in this grant of exemption, the UAS, PIC, and operator must 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The Federal Aviation Administration by and through its authorized representative is 

requested to approve this petition based on the above terms and conditions for a certificate of 

authority and certificate of exemption to operate within the above parameters for compensation 

or hire within the United States National Air Space.

Respectfully submitted:

Willis Chung