Cory Sparkuhl, Sparkle Films LLC, Laguna Beach, CA 

– Section 333 Exemption Petition 

November 17th, 2015 

U. S. Department of Transportation Docket 

Management System 1200 New Jersey Ave, SE 

Washington, DC 20590 

Dear Sir or Madam, 

I, Cory Sparkuhl, owner of Sparkle Films, am writing 

pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F.R.11, 

to request that I, Cory Sparkuhl, owner of Sparkle Films 

LLC, a Video Production Company, and owner/operator 

of 2 small unmanned aircrafts, be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so 

that I, Cory Sparkuhl, may safely operate my unmanned 

aircraft systems (“UAS”) commercially in airspace 

regulated by the Federal Aviation Administration 

(“FAA”). 

Applicant: 
Cory Sparkuhl Sparkle Films LLC 625 Griffith Way 

Laguna Beach, CA 92651 949-338-4332 

cory@sparklefilms.net 

Regulations From Which The Exemption Is 

Requested: 

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 

91.7 (a) 14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 

91.203 14 CFR 91.405 14 CFR 91.407 14 CFR 91.409 

14 CFR 91.417 

(c) 

(a) and (b) (a) (a) (1) (a) (2) 

(a) and (b) 

Extent of Relief and Why: 

14 CFR Part 21 subpart H 

The UAS’s to be operated carry neither pilot nor 

passenger and carry no explosive materials 

or flammable liquids. Given the size, weight, speed, and 

limited operating area associated with the aircraft to be 

utilized, I request exception. In the restricted 

environment and under the conditions proposed 

operation will be at least as safe, or safer, than a 
conventional aircraft operating with an airworthiness 

certificate without said restrictions. 

14 CFR 45.23 (b) 

Due to the size of these UAS’s it does not have a 

cockpit, cabin, or pilot station on which to market 

certain words or phrases. Lettering would be very 

difficult to place on such a small aircraft and dimensions 

would need to be smaller than required minimum. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificate for the 

aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircrafts for

maintenance and use of safety check list prior to each 

flight an equivalent level of safety will be provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS’s have no 

ability to carry a flight manual on the aircraft. There is 

no room, capacity, or pilot on board to adequately carry 

flight manual. An equivalent level of safety will be 

maintained by keeping the flight manual at ground 

control point where the pilot will have immediate access 

to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided 
for the aircraft an exemption will be needed. Normal 

procedures including but not limited to; reviewing 

weather, flight battery requirement, landing and takeoff 

distances, along will all of those found in attachment 

"DJI Pilot Training" (See Appendix D). An equivalent 

level of safety will be provided by preflight protocol to 

properly match the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully 

functional dual controls. Flight control is achieved 

through the use of a control box that communicates with 

the aircraft via radio communications. The equivalent 

level of safety provided because neither a pilot nor 

passenger will be carried in the aircraft, and by the 

speed and size of the aircraft. 

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved 

by current regulations because my UAS’s do not carry 

pilot nor passenger. While helpful, a pilots' license will 

not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS may not have a barometric altimeter, but 

instead does have a GPS altitude read out. An equivalent 

level of safety is achieved by the operator receiving live 

flight data monitoring and confirming current altitude 

along with altitude of launch site shown on GPS altitude 
indicator. 

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and 

configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. There is no 

room, capacity, or pilot on board to adequately such 

documents. An equivalent level of safety will be 

achieved by keeping these documents, to the extent they 

are applicable to the UAS, at the ground control point 

where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 

91.409 (a) (2), 14 CFR 91.417 (a) and (b)Given these 

sections only apply to aircraft with an airworthiness 

certificate, these sections do not apply to this applicant. 

As a safety precaution, operator will perform preflight 

inspections and ensure UAS is in working condition 

before initiating each flight. 

These are in accordance with FAA Publication: Public 

Guidance for Petitions for Exemption Filed under 

Section 333 (Rev. 9/25/14). The petitioner submits this 

application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently 

applicable FARs operating to prevent the petitioner 

from contemplated Commercial Videography 

encompassing Aerial Video Marketing, 

Cinematography, Real Estate, Academic and other 

Video Production related flight operations within the 
national airspace system (NAS). The Reform Act in 

Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace 

system as it is in the public’s interest to do so. The 

petitioner’s ultra light weight UAS’s meets the 

definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of Petitioners 

ultra lightweight UAS’s is expressly contemplated by 

the Reform Act. Petitioner would like to operate his 

ultra lightweight UAS’s prior to the time period by 

which the Reform Act requires the FAA to promulgate 

rules governing such craft. 

I, Cory Sparkuhl, have several years of USA experience 

as well as a Videography background and vested interest 

in the industry. I can provide direct experience and 

valuable information to develop requirements and 

protocols for formal regulation that can be administered 

regarding various applications related to UAS aerial 

video and photography. 

The Reform Act guides the Secretary in determining the 

types of UAS's that may operate safely in our national 

airspace system. Considerations include: The weight, 

size, speed and overall capabilities of the UAS's; 

Whether the UAS will be operated near airports or 

heavily populated areas; and, Whether the UAS will be 

operated by line of sight. 112 P.L. 95 § 333 (a). Each of 

these items reflects in favor of an exemption. Both my 

UASs utilize four (4) counter-rotating propellers for 
balance, control and stability. Our UAS’s are equipped 

with GPS and auto return safety technology. Weighing 

less than fifteen (15) pounds (far below the max. 55-

pound limit); including camera with gimbal. I always fly 

line of sight below 300ft away from populated areas and 

Airports, Hospitals or Heliports. Prior and during every 

flight we adhere to strict pre flight and in flight 

protocols (see appendix C). 

Safety: 

I, Cory Sparkuhl, consider safety as foremost with each 

flight. Both my DJI Inspire 1 and DJI Phantom 2 V1 are 

designed to hover in place via GPS and operate per in 

flight protocol in less than a 13-knot (15 mph) wind. 

Built in safety systems include a GPS mode that allows 

our UAS to hover in place when radio controls are 

released. With three modes to choose from, we utilize 

the Safe Mode for aerial videography/photography. This 

is the safest, most reliable and stable mode to prevent 

accident and hazard. When pilot communication is lost 

UAS is designed to slowly descend to point of take off. 

We are constantly on alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to 

land/abort immediately to the nearest and safest ground 

point should a manned aircraft approach our location or 

we suspect manned aircraft may approach near our 

location. Flights generally last between ten (10) to 

fifteen (15) minutes, with an altitude under three 

hundred (300) feet. Altitude and distance limits are set 
within the firmware (see appendix a and b). Also 

programmed into the firmware are early battery 

warnings starting at 30% battery power remaining. 

Typically we land our UAV’s at no lower then 40% 

battery remaining for further safety precautions. 

How Cory Sparkuhl Sparkle Films LLC Request 

Will Benefit the Public As A Whole: 

1. As the UAV industry and technology takes the 

world by storm the public safety as well as the 

safety of our National Airspace is at hand. I, Cory 

Sparkuhl, owner of Sparkle Films LLC and 

operator of multiple UAV’s takes in Safety as a 

highest priority. In order to ease the tension of the 

unknown it is companies like Sparkle Films that 

will help educate and train both public and new 

UAV users on the safety, regulations, uses and 

applications, and common sense related to do’s 

and don’ts. There is limited manpower and as the 

industry expands its companies like Sparkle Films

and pilots like myself that will assist the FAA in a 

safely integrating UAV’s into the sky. 

2. Other obvious benefits within the Video Production 

industry is the decreased need for manned 

helicopters to capture aerial videography in turn 

reducing the risk of life in the air and on the 

ground. In addition the mentioned quadcopters 

produce less noise and air pollution then 
convention methods of aerial videography. 

3. Sparkle Films will be creating Jobs and 

contributing to the overall local economy as our 

services are expanded into the UAV arena. 

4. Sparkle Films will be able to capture footage that 

otherwise used to be impossible or too costly. This 

cost savings and new perspective will open up 

opportunities to learn more about our 

communities and businesses in a way we could 

have never imagined. 

Summary: 

For the reasons stated below I, Cory Sparkuhl, 

respectfully request the grant of an Exemption allowing 

me to operate ultra lightweight, remote controlled 

UAS’s for the purpose of producing dynamic 

videography/cinematography promoting economic 

growth for the local community while educating the 

public on the correct and safe way of UAS integration 

into the national airspace. 

Lastly The FAA has issued grants of exemption in 

circumstances similar in all material respects to those 

presented in your petition. In Grants of Exemption Nos. 

11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket 

No. FAA−2014−0507), 11112 to VDOS Global, LLC 
(see Docket No. FAA−2014−0382), and 11213 to 

Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), 

the FAA found that the enhanced safety achieved using 

an unmanned aircraft (UA) with the specifications 

described by the petitioner and carrying no passengers 

or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that 

the UAS operation enabled by this exemption is in the 

public interest. 

As described herein I, Cory Sparkuhl, am experienced in 

flying quadcopters and hexacopters currently referred to 

as Drones and owner of a well- established insured 

Video Production Company (Sparkle FIlms LLC) based 

out of Laguna Beach, California. Sparkle Films has been 

in business for over a decade providing video services to 

an array of clients. I currently own and fly a DJI Inspire 

1 Quadcopter and DJI Phantom 2 V1 Quadcopter (see 

appendix A for Inspire and Appendix B for Phantom 2 

V1) with over 200 hours combined flight time on the 

listed UAV’s. I, Cory Sparkuhl, submit this 333 

Exemption with intent and desire to add and utilize this 

technology for the purpose of continuing to produce 

dynamic content and accommodate the request of our 

existing and future client base seeking to utilize this 

revolutionary technology and the unbelievable 

perspective this technology is able to safely capture, 

following exemption and approval by the FAA. I have 
flown Multirotors for over five (5) years without 

incident. 

Committed to safety with each flight. My exemption 

request would permit operation of ultra lightweight, 

UAS(s) for commercial use in tightly controlled and 

limited airspace. Predetermined in areas away from 

general public, airports, heliports and vehicular. 

Furthermore I, Cory Sparkuhl, believe that based on my 

experience and reputation within the video production 

community is in a unique position to assist the FAA in 

developing operational and safety protocols for 

lightweight UAS’s as they are integrated into the 

National Airspace. Currently this seems to be a major 

issue as the drone industry explodes and the uneducated 

take to the skies. I, Cory Sparkuhl, have personally 

instilled safety protocols and controls to avoid and 

prevent public hazard, as well as manned aircraft 

hazards/catastrophe. This will act to further safety 

protocols exclusive to lightweight UAS's specific to the 

Video Production Industry. Currently, similar 

lightweight, remote controlled UAS's are legally 

operated by unmonitored amateur hobbyists with no 

safety plan or controls in place to prevent catastrophe. I, 

Cory Sparkuhl, will continue to record flight data and 

other information gained through permitted flight 

operations to share with the FAA through any required 

FAA reports to assist with future protocol and safety 

regulation. 
Granting my request comports with the Secretary of 

Transportation’s (FAA Administrator’s) responsibilities 

and authority to not only integrate UAS's into the 

National airspace system, but to “...establish 

requirements for the safe operation of such aircraft 

systems [UAS's] in the national airspace system” under 

Section 333(c) of the Reform Act specific to the use of 

UAS's for Cinematography/Photo purposes. Further I, 

Cory Sparkuhl, will conduct my operations in

compliance with the protocols described herein or as 

otherwise established by the FAA. 

As set forth herein, Cory Sparkuhl owner of Sparkle 

Films LLC seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire 1 UAS and DJI Phantom 2 

V1 UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United 

States. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Cory 

Sparkuhl, owner of Sparkle Films LLC to safely, 

efficiently, and economically operate the DJI Inspire 1 

and Phantom 2 V1 UASs commercially within the NAS. 

In accordance with the Federal Aviation Regulations 

and the FAA Modernization and Reform Act of 2012, 
Section 333, Cory Sparkuhl owner of Sparkle Films 

LLC seeks Exemption Request Section 333 of the FAA 

Reform Act of the Federal Aviation Regulations from 

14 CFR Part 21, 14 C.F.R. 91.109, 14 CFR 91.405 (a), 

14 C.F.R. 45.23(b), 14 C.F. R. 91.119, 14 CFR 407 (a) 

(1), 14 CFR 61.113 (a) & (b), 14 C.F.R. 91.121, 14 CFR 

409 (a) (2), 14 C.F.R. 91.7 (a), 14 CFR 91.151 (a), 14 

CFR 417 (a) & (b), 14 CFR 91.9 (b) (2), 14 CFR 91.203 

(a) & (b), 14 C.F.R. 91.103 

Dated: May 21, 2015 

Respectfully submitted, 

Cory Sparkuhl Sparkle Films LLC 625 Griffith 

Way Laguna Beach, CA 92651 949-338-4332 

cory@sparklefilms.net