Bumpy Road Studios

Brandon Shafto

5668 Weir Road

Oscoda, MI 48750

(989) 254-5407

bumpyroadstudios1@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 

91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

Bumpy Road Studios is writing pursuant to the FAA Modernization and Reform Act of 2012 and the

procedures contained within 14 C.F.R. 11, to request that Bumpy Road Studios, an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) 

listed below so that Bumpy Road Studios, may operate a small light weight unmanned aircraft

system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, Bumpy Road Studios is experienced in testing and flying hobby helicopters for 

recreational purposes. Bumpy Road Studios has added a hobby grade quad-copter UAS to their 

inventory equipped with an external camera that produces extremely high quality video. It uses a 

removable 4GB micro SD card. The camera shoots full HD video at 1080p/30fps and 720p/60fps 

with the intent for aerial videography/cinematography to enhance academic community awareness

for those individuals and companies unfamiliar with the geographical layout of the northeast 

Michigan area. To also augment real estate listing videos as well as promotional and commercial 

films for businesses and companies; following exemption and approval by the FAA. Thereby 

enhancing their academic research and visual experience for their greater northeast Michigan 

region.

Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition
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I have flown small RC electric helicopters and fixed wing planes for over ten (5) years without 

incident. Committed to safety with each flight, Bumpy Road Studios exemption request would 

permit operation of light weight (less than 51lbs), unmanned (piloted by remote control) and 

comparatively inexpensive UAS(s) in tightly controlled and limited airspace, predetermined in areas 

away from general public, airports, helipads and vehicular traffic for community videos, and within 

property boundaries for individual homeowner real estate listing videos/photos and business 

owners. 

Currently, similar lightweight, remote controlled UAS's are legally operated by amateur hobbyists 

with no safety plan or controls in place to prevent catastrophe. The pilot of Bumpy Road Studios 

has 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 real estate video and photography usage as recorded 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 Bumpy Road Studios’ 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 real estate purposes. Further, Bumpy Road Studios will conduct operations in compliance with 

the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, Bumpy Road Studios, respectfully request the grant of an exemption 

allowing to operate light weight, remote controlled UAS’s for academic community awareness to 

benefit/stimulate attraction to the greater northeast Michigan area, to add beautiful and unique 

production value to independent motion picture films, to produce promotional films for businesses 

and companies and to enhance real estate listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose. All of which will promote local economic growth 

through increased employment and increased tax base. All the while keeping public safety in mind, 

educating interested hobbits, being a good mentor and offering a solution outside of manned 

aircraft containing combustible fuel that could pose a potential public hazard.

_______________________________

1 Appendix A - DJI Phantom 2 quad-copter Operator Manual

2 Appendix B - Cherry Capital Airport Map area 5 mile airport radius maps

3 Appendix C - Personal Protocols and Control

4 Appendix D – Flight Safety Manual

5 Appendix E – Caution Placard

Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition
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I. Contact Information:

Brandon Shafto, Owner

Bumpy Road Studios 5668 Weir Road 

Oscoda, MI 48750

Office/Mobile: (989) 254-5407 Email: bumpyroadstudios1@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Bumpy Road Studios Requests Exemption are:

14 CFR 21;14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 

CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Bumpy Road Studios seeks and the Reason it seeks Such 

Relief:

Bumpy Road Studios 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 Bumpy Road 

Studios contemplated commercial cinematic, academic and other flight operations within the 

national airspace system. 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. Bumpy Road Studios’s, ultra light weight UAS meets the definition of “small unmanned aircraft”

as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly 

contemplated by the Reform Act. We would like to operate the ultra light weight UAS prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all real estate, motion picture and commercially promotional related 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 reflect in favor of an exemption for Bumpy Road Studios. 

Our UAS utilizes four (4) counter-rotating propellers for balance, control and stability in addition to 

hard mounted aftermarket prop guards. Our UAS is equipped with GPS and auto return safety 

technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including 

camera with gimbal.

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Bumpy Road Studios considers safety foremost with each flight. Our small unmanned aircraft is 

designed to hover in place via GPS and operate in less than a 35 mph wind. For safety, stability and 

fear of financial loss, we will not fly in winds exceeding 15 mph. 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 Smart Mode 4 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 slowly descend to point of take off. We do not operate the 

UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. 

We are constantly on alert for any manned aircraft (Police/Medical/Civilian aircraft, etc.) and 

prepared to land/abort immediately to the nearest and safest ground point should a manned 

aircraft approach my location or we suspect manned aircraft may approach near my location. Our 

UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of 

the operator/pilot, as the remote control pilot. Utilizing battery power rather than combustible 

fuels, flights generally last between three (3) to ten (10) minutes, with an altitude under one 

hundred fifty

(150) feet. 

Bumpy Road Studios utilizes a fresh fully charged battery with each flight as a safety precaution; 

full flight time limit for each battery is 20 minutes as tested. We do not operate the UAS at or 

below manufacture recommend minimum charge levels for operation; preferring to remain well 

within a safe operating range to insure adequate communication between radio control and UAS to 

eliminate potential for loss of control, hazard or crash. Reserve batteries are at hand with each 

operation to insure replacement for sufficient safe level of operation. We do not believe in taking 

risks that may cause a crash, that could create hazard to the public/property/manned aircraft, and 

have no desire to lose an investment. We have clocked numerous flight hours in remote areas as a 

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

of this specific UAS's performance under different temperature and weather conditions. We also 

practice computerized simulated flights to maintain adequate skills and response reflex time. All for

the sake of safety. 

Bumpy Road Studios is extremely cautious when operating the UAS and will not “create a hazard 

to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size 

and weight of the UAS it falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UAS's into the national 

airspace system. Bumpy Road Studios’ UAS, used in hobby flight, has a demonstrable safety record 

and does not pose any threat to the general public or national security.

4 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, andsafety control 

to return home or land in the event of communication interruption between RC transmitter and UAS. See Appendix A - Operator Manual.

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IV. How Bumpy Road Studios’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness, agriculture, motion picture films and for real estate 

marketing has been around for a long time through manned fixed wing aircraft and helicopters. For 

small budget real estate companies and average homeowners the expense of such aerial 

videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners 

can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors 

from a valuable marketing tool.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Furthermore, the 

Michigan Legislature passed a House Concurrent Resolution (HCR 16) in December 2013. 

Supporting Michigan’s Advanced Aerial Systems Consortium as one of the test sites designated by 

the FAA. http://www.legislature.mi.gov/documents/2013-2014/concurrentresolutionadopted/

House/pdf/2013-HACRH-0016.pdf

Granting Bumpy Road Studios’ exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and around the greater Lake Huron 

Coastline and Northern Michigan area. Our ultra light weight UAS is battery powered and creates 

no emissions that can harm the environment. The consequence of our ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain 

combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash-threat by permitting aerial 

video/photo capture through the battery operated ultra light weight UAS's. Permitting Bumpy Road

Studios, to immediately fly within national air space furthers economic growth. Granting our 

exemption request substantially furthers the economic impact for the northern Michigan 

community by aiding wildlife conservation efforts for the Huron National Forest, aiding in industrial 

survey, agricultural efforts as well as individuals looking to relocate for career advancement 

through academic and geographical awareness. All of which serve as a stimulus to the community 

and economy.

V. Reasons Why Bumpy Road Studios’s Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

Bumpy Road Studios', exemption will not adversely affect safety. Quite the contrary, for the reasons

stated, permitting Bumpy Road Studios to log more flight time in FAA controlled airspace, with 

communication with the FAA will allow us to contribute to the innovation and implementation of 

new and novel, as of yet undiscovered safety protocols for Realtors and filmmakers that can be 

Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition
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embraced by the NAR5 and MAR6 for development in cooperation with the FAA. In addition, Bumpy

Road Studios, submit the following representations of enhancements to current aerial videography 

and photography for real estate, commercial promotion and ecosystem conservation: 

Our UAS weighs less than 5 pounds complete with a small ultra light weight high quality HD 

camera; We only operate my UAS below 200 feet7 (well within the 400 foot permissible ceiling set 

by the FAA Modernization and Reform Act of 2012)

• Our UAS only operate for 5-15 minutes per flight

• We land the UAS prior to manufacturer recommended minimum level of battery

power

• We pilot the UAS through remote control only by line of sight

• The UAS has GPS a flight safety feature whereby it hovers and then slowly lands

if communication with the remote control pilot is lost

• We actively analyze flight data and other sources of information to constantly

update and enhance safety protocols

• We only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas

• We conduct extensive pre-flight inspections during which safety carries primary importance

• We always obtain all necessary permissions prior to operation

• We have procedures in place to abort flights in the event of safety breaches or

potential danger

Bumpy Road Studios’ safety protocols provide a level of safety equal to or exceeding existing rules. 

It is important to note that absent the integration of commercial UAS into our national airspace 

system, helicopters are the primary means of aerial video and photography for community 

awareness and real estate. While the safety record of such helicopters is remarkably astounding, 

there has been local incident involving loss of life as well as extensive property damage; it is far 

safer to operate a battery powered light weight UAS. 

First, the potential loss of life is diminished because UAS's carry no people on board and we only 

operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a 

UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and 

extreme maneuverability of our UAS allow Bumpy Road Studios to remotely pilot away from and 

avoid hazards quickly and safely.

_______________________________

5 National Association of Realtors, http://www.realtor.org/

6 Michigan Association of Realtors, http://www.mirealtors.com/

7 DJI Phantom 2 quad-copter altitude ceiling is 147 feet when flown in Smart mode (see Appendix A Operator Manual)

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Lastly, given its small size and weight, even when close enough to capture amazing images, the 

UAS need not be so close to the objects they are focused on through the technology and use of 

post editing software allowing pan and zoom. Accordingly, our UAS has been experimentally 

operated for familiarization/competency and will continue to operate at and above current safety 

levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Bumpy Road Studios' UAS permits exemption from Part 

21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Bumpy Road Studios’ current and projected UAS's meet or 

exceed each of the elements.

14 C.F.R. 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 the FARs, this Regulation is 

inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a safety/flight manual delineating areas of where 

safety can be defined9. The FAA has previously issued exemptions to this regulation in Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS

utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level of 

safety will be achieved by maintaining any such required certifications and registrations by the 

owner, Brandon Shafto.

9 Appendix D - Safety/Flight Manual

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B. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Our UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to 

place on such small aircraft with dimensions smaller that minimal lettering requirement. 

Regardless, we will mark its UASs in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone 

assisting me as a spotter with the UAV will see the markings. The FAA has previously issued 

exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and

10700.

C.14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. 

Bumpy Road Studios, can achieve an equivalent level of safety as achieved by current Regulations 

because our UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will 

not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing Bumpy Road Studios to operate their UAS meet and exceed current safety levels in 

relation to 14 C.F.R. §61.113 (a) & (b).

D.14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to

be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude 

greater than 200 AGL; safely below the standard of 400 AGL. Bumpy Road Studios, will however 

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

equivalent to or below those in relation to minimum safe altitudes. Given the size, weight,

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

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, among other things, aircraft owners and operators to “have 

[the] aircraft inspected as prescribed in subpart E of this part and shall, between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. . . .”

Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition
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These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, 

apply to Bumpy Road Studios' UAS. However, as a safety precaution we inspect my UAS before and

after each flight and conduct relevant maintenance pursuant to manufacturer specifications.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness 

Certificates, sets forth requirements for procurement of necessary airworthiness certificates in 

relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits 

exemption from Part 21 because Bumpy Road Studios' UAS meets an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity 

to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 

14 C.F.R. 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 the FARs, this Regulation is 

inapplicable. 14 C.F.R. § 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 UAS's, this Regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions

to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any 

damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Bumpy Road Studios seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R.

§ 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 

C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 

C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially 

operate my, Bumpy Road Studios', small unmanned vehicle/lightweight unmanned aircraft

vehicle in community awareness and real estate operations, and to develop economic platforms for

real estate to enhance the experience of those seeking to relocate to the northern Michigan area. 

Currently, area awareness and real estate aerial videography/photography relies primarily on the 

use of larger aircraft running on combustible fuel posing potential risk to the public. Granting 

Bumpy Road Studios' request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS craft does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from established 

air fields. Bumpy Road Studios has been informally analyzing flight information and will compile 

safety protocols and the implementation of a flight operations

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manual that exceeds currently accepted means and methods for safe flight. Formal collection of 

information shared with the FAA will enhance the FAA's internal efforts to establish protocols for 

complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board 

Bumpy Road Studios’ UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. Bumpy Road Studios' operation of the UAS, weighing less than 5 pounds 

and traveling at lower speeds within limited areas will provide an equivalent level of safety as that 

is achieved under current FARs. Accordingly Bumpy Road Studios, respectfully request that the FAA

grant our exemption request and are willing to cooperate in sharing information to benefit the FAA, 

safety of manned aircraft, and the general public at large.

Specifics of the UAS;

UAV/UAS/UA Clarification

The UAV/UAS/UA which Bumpy Road Studios, Petitioner, will be operating is the DJI Phantom 2, 

referred hereafter as Phantom. The inherent safety features, sophistication, the ability to program, 

GPS navigation, return home capability, airport vicinity no-fly feature and restricted altitude 

feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the 

camera make this a much safer UAV for the purposes of this petition. This is a hobby grade radio 

controlled UAV that has the capacity for software upgrades. It is light, less than 5 pounds including 

battery and camera. Incorporated into the programming of the Phantom is an automatic return 

home feature that automatically directs the craft back to point of take off should communication

with the transmitter be lost. The Phantom has a cruising speed of 20 mph, with a maximum speed 

of 36 mph. Maximum flight time is 20 minutes. Gross weight is 2.86 pounds.

The Phantom has an additional communication link between the camera and craft on a different rf. 

Allowing the operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL), distance 

from PIC, camera imagery, and control camera angle.

The software for the Phantom allows the operator or PIC to set maximum altitude AGL for each 

flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as an 

examples. The 400 foot maximum AGL can be programmed into the UAV's software pre-flight to 

insure compliance with FAA standards adding to the safety capabilities of this UAV. This UAV is 

programmed to remain in position when controls are released. Maintaining altitude and GPS

location. 

The Phantom has an altitude and radar monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator PIC. The operator or PIC 

can monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS locking

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so the operator or PIC can land the UAV as a precaution. Best explanation of the Phantom's 

sophistication and capabilities can be observed through a series of manufacture videos explaining 

the Phantom 2 through this link ( https://www.dji.com/product/phantom-2 ). The Phantom 2 

maintains all capabilities defined in the video. 

The DJI Phantom 2's 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf 

transmitter/receiver for video/photography functions eliminates the rf conflict experienced with 

the Blade 350 QX, and is by far the safer of the two when considering public and NAS safety. 

Considering the programmability and safety features of this UAV (Phantom 2), it serves as the best 

option to protect the Public and NAS for the purposes of this petition. 

The Bumpy Road Studios Petition is for UAV operation without pilot, passengers nor property on 

board. Considering that the Phantom UAV is a sophisticated hobby grade quad-copter with gross 

weight less than 3 pounds. Aerial video/photography operations for this petition provide service for

those businesses, transferees, retirees and others considering relocating to greater northeast 

Michigan region who are not familiar with geographical characteristic, communities, services and 

other benefits of the area. Aerial video/photography operations for private property owners aide 

with an enhanced perspective for characteristics, amenities, and benefits a private property has 

that cannot be displayed through ground level video/photography. Petitioner, Bumpy Road Studios 

charges no additional fees for ground level video/photography. Therefore, there is no compensation

for these services. Aerial video/photography represent a small portion of videos and photos 

currently offered at ground level for the community as well as private properties marketed for sale. 

Aerial video/photography is an enhancement to videos/photography already offered homeowners 

and the public. In most cases aerial video will represent 4-20 seconds of a 2-3 minute video.

Petitioner Bumpy Road Studios is using a UAV that has the capability for taking off and landing at a 

single point, identical to a helicopter. There are no runways, aided take off apparatuses, nor routes 

that need to be flown to areas being aerial video recorded or photographed. Allowing a reduced and

more confined area of flight. 

Home owner and business written consent for aerial video/photography shall be obtained prior to 

flight. Observer(s) to assist/warn/advise the PIC, will be utilized in situations where spectators 

may be within 500 feet of the flight area. 

To alleviate additional privacy concerns, petitioner also has the ability to cover up areas in movie 

post-production by shading out objects (people/buildings) in the immediate vicinity. 

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The single UAV utilized in this petition is a hobby grade quad-copter that does not require an 

airman certificate for non-commercial flight involving less restrictive less regulated flight. UAV 

flight competency can be verified/obtained through AMA standards and procedures as well as 

downloading the flight data from the on board data logger.

The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition 

are not complicated. Engineering and design allows layman maintenance. Recording part 

replacement for this UAV may prove redundant due to the simplicity of the craft. While the 

Petitioner requests waiver or exemption for maintenance records, it would be understandable if the

FAA requires such data for its rule making process. However, pre-flight inspection for cracks, 

damage or other physical conditions that could hamper safe flight is a reasonable expectation. As 

well as post flight inspection that may aid in identifying flight conditions that may cause stress to 

propellers, landing gear, etc.

Thorough inspection of UAV shall be conducted and flight response tested should a hard landing or 

crash occur. Insuring that the UAV can operate in a safe manner before conducting any further 

video/photography.

Petitioner requests waiver or exemption for markings due to the small size of the fuselage for the 

Phantom 2 .

Petitioner requests modification waiver or exemption and clarification (within reason) concerning 

section 91.119 prohibition of flight in congested areas. Such restriction puts home owners in 

subdivisions and business owners on downtown streets at a disadvantage by limiting enhanced 

marketing of their homes and businesses; thereby discriminating against them. Vertical takeoff and

landing while video recording or photographing can allow an enhanced perspective for view or 

proximity of mountains, golf course, man made lake or other attractions not possible through 

ground level video recording or photography. Petitioner requests waiver for this condition to allow 

reasonable and responsible aerial video/photography in congested areas of subdivisions , 

neighborhoods and downtown areas. In cases where altitude within airports is an issue, aerial 

video can be achieved under 100 feet.

In compliance with Section 90.151 (a) the Phantom is a battery operated UAV/ UAS with battery 

level monitoring capability. Fully charged battery flight time is rated at 20 minutes, with 

videos/photos taking much less time to record. Operator or PIC is warned when battery level is low.

Petitioner requests waiver/exemption from Section 91.203 (a) since the Phantom is a hobby grade 

UAV/UAS that should not require an airworthiness certificate nor a registration certificate. Posting 

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of special flight authorization would not be possible since the Phantom has no cabin and is not 

large enough to carry a certificate. However, a special flight authorization can be maintained by the

operator to make available upon request.

DJI Phantom 2 

UAS Certificate Number: FA3RE4P7EK

1 Height limitation set for maximum of 300 feet AGL

2 Radius distance from controller set for maximum of 1000 feet

3 Both to aid in VLOS

4 Flight testing at the R/C air park has proven that due to UAS size of the Phantom 2, firmware 

programmed for maximum 300 feet AGL and 1000 distance are limited distance for maintaining 

VSOL without assistance of binoculars or other assistance. Most intended operation will only 

requires range of 20-100 AGL and less than 200 feet lateral distance from PIC. Limited stated 

distance for VSOL will be rare if ever needed.

Current firmware upgrades for

5 Main Controller

6 GPS

7 Receiver

8 Battery

9 Zen IMU

Petitioner would like to seek a reasonable exemption with restriction solely to UAS operation at 

AGL below 300 feet with distance of flight no greater than 1000 feet. Currently there are no 

provisions within the FAA for governing UAS such as the DJI Phantom 2 for hobby or commercial 

use in northern Michigan. With Phantom 2 alone sales have been "...exponentially higher than the

7,500 in 5 years estimate that the FAA put forward a year ago..." UAS potentially being flown 

without guidelines by unfamiliar, untrained individuals not belonging to professional organization 

like the AMA, who pose a threat to NAS, the public and responsible parties like the Petitioner.

Respectfully submitted,

Brandon Shafto

Bumpy Road Studios

5668 Weir Road

Oscoda, MI 48750

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PHANTOM Flying Flowchart V1.0 (Simplified Version)

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Appendix A

DJI Phantom 2 Owners Manual

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

Instead of inserting a pdf into this document, link 

is provided for immediate viewing 

and download.

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Appendix B

Wurtsmith Airport Vicinity and 5NM Circle

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Appendix C

Protocols and Controls

Aerial Community, Commercial videography/photography and Motion Picture Films

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight.

Pre-Flight Protocol:

Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries for 

damage or leakage that may affect proper operation. Inspect propellers for cracks, chips or damage

that may cause sudden loss of propulsion or unmanageable/uncontrolled flight. Check weather 

forecasts for wind advisory or other conditions that my impact flight.

Consult five (5) mile radius map for airport vicinity.

o Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information.

Inspect flight area for

o vicinity of public safety helipads/heliports

o vicinity of medical helipads/heliports

o vicinity of light poles

o vicinity or utility wires

o vicinity of trees

o flocks of birds that may cause interference and potential flight impact

o vicinity of any elevated obstructions that may pose potential flight hazard

o vicinity of roadways with moderate to heavy traffic that can be distracted

o public gatherings that may attract viewers

o optional point of control for best visual site of UAS while in flight

Takeoff and landing

o inspect area for best and safest point of takeoff and landing

o if in a subdivision or area that is within 150 feet of a residential street, post warning 

sign(s)/stand(s) "Attention Aerial Photography In Progress – Remain Back 150 Feet "

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Flight Protocol:

-Takeoff and land from same location

-Remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

-Do not allow anyone to engage in conversation or distract the remote control pilot 

-Restrict flight to minimal elevation sufficient to acquire desired results

-Remain prepared for emergency landing at all times

-Pay attention to flight time

-Set a timer as a safety alert when applicable

-Land UAS and shut down propulsion immediately following landing

Post flight:

-Power down all electrical systems

-Remove and stow batteries according to manufacturer guild lines

-Visual inspection of flight controls, flight propulsion systems, landing gear, and rf controllers

-Stow Phantom 2 and supporting equipment according to manufacturer guidelines

Emergency or Suspected Hazard:

-Immediately land UAS at safest and closet ground location 

-Manned aircraft is heard or seen in vicinity of flight

-There is a public gathering within established safety boundary wanting to observe flight. Advice 

public gathering of posted signs and ask to clear LZ

-Pilot is being distracted from focusing on flight and safety

-Sudden change in weather (wind gusts, precipitation, lighting)

-Sudden increase in vehicular traffic in vicinity of flight

-Birds enter into proximity of flight

-Any sudden unsafe event that can cause collision, distraction or interruption of control

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Appendix D

Flight Safety Manual

Checklist Format

(See next page)

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Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition

Arrival Checklist After Takeoff Checklist

1. If day and operation out of back of 1. Hover approximately ten feet above the

vehicle into sun ground to confirm UAS is under control

2. Remove case and place on level surface. 2. All sticks operate correctly while in hover – verified

3. Check distance to nearest airport and/or 3. Video communications – broadcasting

tablet app. 4. Gimbal operation – pitch, yaw, tilt

4. If required, use VHF aviation transceiver,

to contact tower of field if closer than 5 NM Pre-Landing Checklist

5. Inform tower/CTAF of UAS ops, location, 1.Camera -full up

and max height of flight. 2.Video recorder – stop

6. Visually inspect rotors, props, fuselage, 3. LZ – clear/safe

landing skids

7. Setup “Caution, aerial photography in Post-Landing Checklist – Returning to Flight Immediately

progress. Remain back 50 yards.” sign 1. Battery – Remove and replace

2. Radio connection to monitor – verified

Preflight Checklist 3. LZ – clear/safe

1. Remove transmitter. 4. UAS battery – on

2. Router – On 5. Camera – full up

3. Transmitter – on 6. Satellite connections – verified

4. Toggle Switches – full up 7. Battery charge levels – safe for flight

5. Video monitor – on 8. Video recording – start

6. Remove UAS from case 9. Takeoff

7. Gimbal lock & lens cal – removed

8. Micro SD card – inserted End of Ops Checklist

9. UAS battery – inserted 1. Battery – off

10. Place UAS in clear and safe launch and 2. Transmitter – off

recovery position if it returns to home 3. Video transmitter – off

11. UAS battery – on 4. Recording off

12. Radio connection to video monitor – on 5. Remove and stow battery

13. Camera – full up 6. Notify Tower/CTAF – end of ops

Satellite connections – verified

14. Battery charge levels – safe for flight Weather

15. Video recording – start

16. Takeoff Surface Obs

Sky:

Vsby:

Temp:

Wind:

Gusts:

Perfip:

Weather at altitude:

Flight level winds:
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Appendix E

Caution Placard

Bumpy Road Studios, Oscoda, MI- Section 333 Exemption Petition