Elevated Studios LLC

Chris Rosepink

20550 E Lake Circle

Aurora, CO 80016

T 720-279-8554

chrisr@elevated-studios.com

June 26, 2015

US Department of Transportation

Docket Operations

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 33 of the FAA Reform Act of the Federal Aviation Regulations

Dear Secretary of Transportation,

 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 

Part 11, Elevated Studios LLC requests to be exempted from the Federal Aviation Regulations 

(FAR) to allow commercial operation of its UAS with the operations before performed within the 

conditions outlined herein or by the FAA as required by Section 333. Elevated Studios LLC is an 

aerial photography and videography company using a DJI Inspire 1 UAS providing services for 

real estate and construction companies with marketing materials. 

 Elevated Studios LLC is owned by Christopher Rosepink. I have hired a pilot for my flight 

operations, Jason Burnett. Mr. Burnett has a Commercial Pilot’s License and second class 

medical certification. Mr. Burnett will be the pilot in command, he will adhere to all FAA guidelines 

and will keep the public’s safety and right to privacy safe guarded at all times. 

 The FAA has issued grants of exemption in similar circumstances in exemption numbers 

11897, 11062, 11109, 11112, and 11213. Based on this Elevated Studios LLC is also requesting 

exemption for the use of a UAS in a commercial setting. 

The following information is provided based on the requirements for filing an exemption: 

Contact Information

Chris Rosepink

20550 E Lake Circle

Aurora, CO 80016

720-279-8554

chrisr@elevated-studios.com

Requesting Exemption from the following sections of Title 14 

14 CFR 21, 14 CFR 45.23 (b); 14 CFR 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)&(b) (2); 91:417(a)&(b) 

PIC Information
Jason Burnett 

Commercial Pilot, FAA 2718263

Second Class Medical

Advanced Ground Instructor

4.25 hours with UAS

48 takeoffs and landings with UAS

Performed training provided by the manufacturer online for the UAS

Visual Observer

A visual observer will be used for commercial flights. The visual observer will be a second set of 

eyes to help ensure safety. The visual observer will be informed of their role prior to each flight 

which includes ensuring the UAS is keeping a safe distance from any objects and that people are 

not in any harm. The visual observer will be in close proximity of the PIC or use two-way radios 

to communicate with the PIC. 

UAS Operation and Safety

The purpose of the commercial use of the UAS will be to provide photos and/or videos of real 

estate. This will not adversely affect safety since the UAS is very small it would be flown in a limited area, the UAS is not carrying a pilot or crew, and does not carry flammable fuel. The UAS 

would be used over the property needing photos/videos which could be a residential house, a 

commercial property, or potential building site. 

The following will be considered as the binding limitation of operations for Elevated 

Studios LLC, 

Elevated Studios LLC uses a DJI Inspire 1 UAS weighing less than 55 pounds, operates at 

speeds less than 50 knots and has the capability to operate in the vertical and horizontal plane 

simultaneously. The UAS will operate only within the line of sight of the operator within a 

protected flight area and at 400 feet AGL or less. These will not present a hazard to the national 

airspace nor the public. The very small nature of these UAS being used in a limited area allows 

for the safe operation that exceeds requirements established by congress.

1. Flights will only occur in the day time hours.

2. Flights will be operated in the line of sight of the operator( PIC) and Observer (VSO). 

3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” based 

on manufacturers recommendations. 

4. The UAS will weigh less that 55 lbs. 

5. Flights will be operated at 400 feet AGL or less. 

6. Crew will be at a minimum the operator (PIC) and an Observer (VSO). 

7. Operator and crew will remain in contact during the flight operation.

8. The UAS operator will perform a check of the flight area and make certain the safety of all 

persons in the area. 

9. All required FAA clearances will be obtained and distances from airports strictly observed. 
10. The UAS has the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working. 

11. Flights will only operate in VFR conditions. 

12. A pre-flight safety inspection will be performed on the UAS which includes checking to ensure 

the UAS is not damaged and all systems are functioning safely. 

13. UAS has a function on the control to tell operator the distance away from the operator and its 

battery power remaining. If the UAS loses communications or GPS signal it will have 

capability to return to a pre-determined location and land. 

14. Flight team will communicate by voice and the use of two-way radio if the area is too big to 

hear voice from all team members. 

15.The maximum total flight time for each flight will be 20 minutes. Flights will be terminated at 

25% battery power reserve if that were to occur during the 20 minute flight. 

16. When operating over or near water the UASs will be equipped with flotation devices so that 

recovery can be made as to prevent lithium battery exposure to the water table.

17.The UAS will operate within the state of Colorado. 

18.The UAS will never enter any restricted airspace or violate any TFR. 

19.PIC and VSO will be trained in operation of the specific UAS.

20.Written and/or oral permission from the relevant property holder will be obtained. Images of 

people will rarely occur, but if they did we will obtain consent prior to operations. 

21. We carry Professional Liability Insurance of 1.5 Million. 

DJI Inspire 1 Specifications

Model	 	 	 	 T600

Weight (Battery Included)	 	 6.47 lbs.

Hovering Accuracy:

Vertical	 	 	 1.6 feet

Horizontal	 	 8.2 feet

Max Angular Velocity	 	 150 degrees

Max Tilt Angle	 	 	 35 degrees

Max Ascent Speed	 	 16.4 ft/s

Max Decent Speed	 	 13.1 ft/s

Max Speed	 	 	 42 kts

Max Flight Time	 	 	 20 minutes

Operating Temperature Range 14-104 degrees farenheit

Dimension
 
 
 18”x18”x12”

Camera 
Model: FC350

Total Pixels: 12.76M

Image Max Size: 4000x3000

FOV (Field of View): 94 Degrees

Lens: 20mm (35mm format equivalent)f/2.8 focus at Infinity

 9 Elements in 9 groups

 Anti-distortion

Still Photography Modes: Single Shoot

	 	 Burst shooting: 3/5/7 frames

	 	 	 Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

	 	 	 Time-Lapse

Video Recording Modes: UHD (4k) 4096x2160p24/25, 3840x2160p24/25/30

	 	 	 FHD 1920x1080p24/25/30/48/50/60

	 	 	 HD 1280x720p24/25/30/48/50/60

Max Bitrate of Video Storage: 60 Mbps

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These 

are inapplicable. The equivalent level of safety will be achieved by maintaining such certifications 

and registrations at Elevated Studios LLC operations center. 

14 CFR 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by FAR’s this regulation is 

inapplicable. 

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs this regulation is inapplicable. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. Elevated Studios LLC 

will only operate its UASs at or below 400AGL. They will be operated on a well defined AOR that 

has been carefully reviewed for hazards and minimizes the presence of any persons not essential 

for these operations. Flights will only be over private property that the owner has consented and 

all persons within this video area also give consent for this filming. Compared to flight operations 

of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating 

below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public. 

Summary

Approval of these 333 Exemptions allowing commercial operations of small UAS in the service of 

aerial photography will greatly enhance safety by reducing the overall risk associated with 

traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly 

in close proximity of populated areas and people in general. With the use of small UAS of 55 lbs. 

or less, battery operated and flying below 400 feet AGL the risk of injury to people on the ground 

or the crew has been reduced or almost erased. The granting of the use of these small UASs by 

Elevated Studios LLC will give the people another avenue to obtain aerial photography and 

videography. 

I appreciate your time regarding this matter and look forward to your response.
Sincerely,

Chris Rosepink