U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. S.E.

Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 from 14 C.F.R. Part 21; 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 

C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 61.113; 14 C.F.R. 

91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 

91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151; 

14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 

14 C.F.R. 91.407; 14 C.F.R. 91.409; and 14 C.F.R. 91.417.

Dear Sir or Madam:

550 Productions, LLC, a Colorado Limited Liability Company, seeks an exemption 

to certain Federal Aviation Regulations (FARs) pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (the Reform Act) and Part 11 of Title 

14 of the C.F.R. 550 Productions, LLC is an organization providing aerial 

photography and cinematography services utilizing Small Unmanned Aircraft 

Systems (sUASs) in the creation of real estate listing advertisement materials 

mainly for large estates in rural areas and for commercial film productions. 

Additionally, 550 Productions occasionally engages in a variety of aerial surveying 

activities including orthomosaic mapping which aids various businesses in project 

management by helping to create survey grade imagery which can be used for

extracting volumetric data and conducting other geospatial analytics.

Approval of exemptions for 550 Productions, LLC will allow commercial sUAS

operations in primarily remote, rural areas across Colorado for real estate 

photography and cinematography, and – to a lesser extent – in filmmaking

productions and other environments where a conventional aircraft would be 

cumbersome at best, and pose severe safety risks at worst. 550 Productions, LLC 

intends to employ a pilot who will act as the Pilot-in-Charge (PIC) having, at a 

minimum, a private pilot certificate and 3rd-class medical certificate. This pilot 

will receive flight instruction specific to the aircraft used by 550 Productions, LLC 

from Mr. Joshua Keffer, who has over 500 hours of flight time with various 

sUASs.

This exemption request should be granted because the use of the aircraft utilized by 

550 Productions, LLC under the conditions and limitations proposed below will 
meet or exceed an equivalent level of safety as Congress has intended. 550 

Productions LLC’s sUAS, the DJI Inspire 1, weighs just 6.5 lbs. The lightweight 

aircraft covered by this exemption request are far safer than the alternative: 

manned aircraft weighing thousands of pounds and carrying hundreds of pounds of 

combustible fuel. Similar sUAS operations have already been approved in 

Exemption No. 11138, Douglas Trudeau, Realtor and Exemption 11136, Advanced 

Aviation Solutions. In all cases, flights undertaken by employees of 550 

Productions, LLC will be conducted with safety as the paramount goal. All flights 

will be at low altitudes and operators shall use pre-programmed, GPS guided flight

patterns whenever possible. No flights shall begin unless the aircraft has first 

acquired an adequate GPS signal for tracking purposes from the ground station and 

GPS-aided flight. 

If you have need of additional information for the assessment of the exemption 

request please do not hesitate to contact us at 719-235-2220 or 

josh@550productions.com. 

Thank you,

Joshua L. Keffer

Owner/President of 550 Productions LLC
I. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. Part 21; 14 

C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29;

14 C.F.R. 61.113; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 

C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 

C.F.R. 91.121; 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.215; 14 

C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 91.409; and 14 

C.F.R. 91.417. Approval of these exemptions for 550 Productions, LLC will allow 

commercial operations of sUASs for the purpose of producing real estate 

marketing materials, and secondarily for commercial filmmaking and aerial survey 

and inspection activities. The exemption should be granted because the operations 

proposed by 550 Productions, LLC, using unmanned sUASs weighing no more 

than 10 lbs., conducted according to the conditions and limitations discussed below 

will provide a level of safety exceeding that of traditional aerial operations 

utilizing manned aircraft. Each of the factors identified by the Congress in 

approving this exemption process under Section 333 – size, weight, speed, 

operational capability, proximity to airports, proximity to populated areas, and 

operation within visual line of light – supports approval of the exemptions sought 

by 550 Productions, LLC. Specifically, the sUASs weigh no more 10 lbs., flight 

will be restricted to class G airspace at altitudes no greater than 400 feet AGL and 

at speeds no greater than 35 knots, and no flights will be conducted unless the 

aircraft has first acquired an adequate GPS signal to enable GPS-aided flight. 

II. Contact Information 

550 Productions, LLC 

3530 Birnamwood Dr. 

Colorado Springs, CO 80920

Tel: 719-235-2220

E-Mail: jonathan.bracewell@gmail.com 

III. 550 Productions, LLC’s Operations

A. The sUAS
550 Productions, LLC currently operates one model of aircraft: the DJI Inspire 1. 

The market for aerial imagery is rapidly evolving, and there are market forces 

which pressure vendors to constantly upgrade equipment. These facts, combined 

with the length of time it takes to receive a grant of exemption, may make it 

difficult to operate in the market with current equipment: by the time the 

exemption for the specific aircraft is granted, those aircraft may very likely be 

outdated and/or obsolete. Therefore, 550 Productions, LLC requests that any 

exemption granted extend not only to aircraft currently owned by 550 Productions, 

LLC, but also to any future sUASs owned by 550 Productions, LLC that meet the 

following criteria: 

1. The sUAS weighs no more than 10 lbs. at takeoff.

2. The sUAS has GPS capability which aids its flight. 

or 

1. The sUAS has already been approved for commercial use by a published FAA 

Grant of Exemption. E.g. the SenseFly eBee permitted in Exemption No. 11136, 

Advanced Aviation Solutions. 

Without abandoning the above request, 550 Productions, LLC explicitly requests 

the exemption allow the operation of the DJI Inspire 1. The sUAS is a batteryoperated multirotor aircraft weighing less than 10 lbs. 

Respectively, the sUAS employed by 550 Productions, LLC have the following 

specifications: 

Airframe: DJI Inspire 1 Flight Control System: The built-in flight control system 

contains the MC (main controller), GPS + GLONASS processor, IMU (inertial 

measurement unit) and compass. The MC is the brains of the system, receiving 

thousands of bits of data each second and translating that data for optimal flight 

stability. The GPS processor now includes the capability to receive signals from 

the Russian-built GLONASS satellites, which improves positioning accuracy and 

quicker satellite acquisition. The IMU contains a 6-axis gyroscope as well as an 

accelerometer. 

Max takeoff weight: 6.5 lbs. 

Max flight speed: 43 knots 

Max ascent/descent speed: 16.4 ft/sec; 13.1 ft/sec 

Battery type: 6S LiPo, 22.2V, 4500mAh 
The aircraft has distinct failsafe capabilities. The Inspire 1 continuously estimates 

the amount of battery power required to fly the aircraft back to the Home Point. 

Once this level of battery power is reached, a message will appear within the flight 

control program alerting the operator. 550 Productions, LLC employees will 

always attempt to return the aircraft to the Home Point when this message appears. 

If no action is taken, the aircraft will automatically fly up to a pre-set altitude, then 

fly to the Home Point and land (this is the return-to-home function or RTH). 

Additionally, the flight software will automatically conduct an RTH if the signal 

from the remote controller is lost for more than three seconds. Before each flight, 

the operator will inspect the area where the flight will take place and note the 

tallest obstruction. The operator will then set the failsafe altitude to a height greater 

than the tallest object in the area. 

The sUASs has a limited range due to the physical limitations of the transmissions 

from the remote controller. In field conditions, this limited range is generally not 

greater than 1,000-1,200 meters or roughly 3,300-3,900 feet. 

The sUAS has the capability for a maximum altitude to be set prior to each flight. 

This is a separate setting from the maximum altitudes which are unchangeable and 

are set by the manufacturer from the factory. Using GPS data to determine altitude, 

the sUAS will not violate either of these altitude limit parameters. 

Please refer to the respective user manuals for the aircraft which are attached to 

this petition as Exhibit 1 for additional information.

B. Flight Conditions 

The sUAS will be flown in airspace no greater than 400 feet above ground level 

(“AGL”) and under controlled conditions in predominantly rural areas. When not 

operating in a rural environment, such as a closed filming set or location, the 

operations will be conducted with strict personnel access controls as needed to 

ensure the safety of all personnel in the area. All personnel in the area will be 

informed of the sUAS flight and will be given proper safety instructions prior to 

take off. The majority of flights will occur in rural areas of Colorado over real 

estate properties that are typically greater than 250 acres in size. 550 Productions, 

LLC will work with the local FSDOs to ensure each operation is conducted in a 

way that avoids conflict with other ongoing operations in the NAS. The aircraft 

will be flown only in class G airspace during VMC, visual meteorological 
conditions: no less than 500 feet below and no less than 2,000 feet horizontally 

from a cloud and with visibility at least three statute miles from the PIC. 

C. Flight Operations 

550 Productions, LLC will require every operator to fly the aircraft within visual 

line of sight (VLOS) of the operator as well as a second individual previously 

designated as the visual observer (VO). Flights shall always be conducted in class 

G airspace at or below 400 feet AGL and at speeds no greater than 35 knots. The 

PIC shall have at a minimum a private pilot certification as well as a third class 

medical certificate. Each PIC will undergo hands-on training with the sUASs and 

achieve a minimum of 10 flight hours before flying for a client of 550 Productions, 

LLC. 

All operations will comply fully with applicable state and local laws. The majority 

of flights will take place over real property exceeding 250 acres. The PIC will 

coordinate with the local FSDO when planning operations. The PIC will consult 

aeronautical charts and review the relevant weather data prior to each operation, 

and brief other members of the flight crew on his findings before each operation 

begins. During the planning phase of each operation the flight crew will ensure that 

the sUAS has the most recent firmware updates from the manufacturer so that the 

sUAS will operate using the most up-to-date controls and parameters from the 

manufacturer. The flight crew shall perform this firmware check no more than one 

week prior to the scheduled flight. 

The flight crew will utilize various measures to ensure that non-participating 

persons do not accidentally enter the flight area. Such measures may include 

locking the gate to a ranch prior to the flight, or setting orange cones and warning 

signs around the area where the flight will occur. The flight crew will always work 

with property owners and/or the film producers and crew to ensure unnecessary 

personnel are not present during the flight. 

Before conducting any operations, the flight crew will inspect the components of 

the sUAS for any visible indications of damage. The crew will then turn on the 

sUAS and allow it to conduct its full self-diagnostic test which each sUAS 

performs upon startup. The flight crew will ensure that the sUAS has acquired its 

GPS signal and then calibrate the onboard compass. No flights (including the test 

flight) shall take place unless the sUAS has acquired a GPS signal the compass has 

been calibrated properly in accordance with the respective sUAS user manual, and 

the sUAS has passed its self-diagnostic test. Next, the PIC will verify that the 
altitude limit in the flight control program has been set to 400 feet AGL. The crew 

will then initiate a brief test flight, bringing the sUAS to 15 feet AGL in order to 

check the flight controls and camera operation. After performing as many 

maneuvers as the PIC finds necessary, but never exceeding more than 100 ft 

horizontally from the ground station, the test flight shall conclude and the PIC shall 

bring the aircraft back to its Home Point. Every Home Point shall be prominently 

marked with orange cones or white engineering tape or some other method of 

marking which provides a similar level of visibility. 

The VO shall make use of a separate video monitor to assist in maintaining visual 

contact with the sUAS. This monitor will display images received wirelessly from 

the camera onboard the sUAS. 

At any time during the flight, should the aircraft lose connection with the remote 

control, the flight control system failsafe will be activated automatically, and the 

aircraft will make a controlled descent either in place or to the Home Point as 

dictated by the aircraft’s capabilities and weather conditions. 

In addition to these safeguards, DJI has programmed into the firmware of each 

sUAS certain “no-fly zones” which will prevent flights in restricted airspace. See 

Exhibit 1 on page 46-48. Any DJI sUAS will not start its motors in these preprogrammed no- fly zones, or if it enters this space during an ongoing flight, the 

sUAS will automatically descend to an altitude outside of the no-fly zone, or 

commence landing. 

During flights, the PIC and the VO will stand next to each other in constant voice 

contact at the ground station. If weather conditions suddenly make continued flight 

unsafe, the PIC will fly the sUAS to a safe altitude above all local obstructions and 

bring the sUAS back to the Home Point or alternatively use the camera to locate a 

safe secondary landing area if the weather conditions are such that returning to the 

Home Point is either not feasible or not safe. 

Flights will be limited to 75% of the battery life of the sUAS. This information is 

indicated on the sUAS itself by flashing lights and also on the remote controller’s 

video screen. 

When performing aerial survey operations by pre-programmed, automated flight 

patterns, the PIC will maintain positive control of the remote controller in the event 

a manual override in necessary. All procedures will remain the same for this type 

of operation with the following exceptions: 
1. The flight crew shall thoroughly inspect the area to be surveyed and note all 

obstructions. 

2. The PIC shall set the automated flight altitude at a level certain to clear the 

obstacles observed by the flight crew. 

3. The PIC shall coordinate with the site foreman, or a person of similar 

responsibility to determine the best time of day during which to conduct the 

operation. 

IV. Aircraft and Equivalent Level of Safety 

550 Productions, LLC proposes that the exemption requested herein apply to any 

civil aircraft that have the characteristics and that operate with the limitations listed 

herein. These limitations provide for at least an equivalent or higher level of safety 

to operations under the current regulatory structure. 

These limitations and conditions to which 550 Productions, LLC agrees to be 

bound when conducting commercial operations under an FAA issued-exemption 

include: 

1. The sUAS will weigh less than 10 lbs. The DJI Inspire 1 weighs 6.5 lbs. 

2. Flights will be operated within VLOS of the PIC and VO and only during VMC. 

3. Maximum total flight time for each flight will be 75% of battery life. Flights will 

be terminated once the battery reaches a 25% level. This information is transmitted 

to the remote controller as well as indicated by flashing lights on the sUAS itself. 

4. The sUAS will remain clear and yield the right of way to all other manned 

operations and activities at all times. 

5. Flights will be conducted at an altitude not to exceed 400 feet AGL. 

6. Minimum crew for each operation will consist of the PIC and VO. 

7. A briefing from the PIC will be conducted in regard to the planned sUAS 

operations prior to each day’s activities. It will be mandatory that all personnel 

who will be performing duties in connection with the operations be present for this 

briefing. 
8. The operator will obtain a FAA Civil COA prior to conducting any operations 

under this grant of exemption. 

9. The operator will request a Notice to Airman (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation. 

10. The PIC and VO will at all times be able to communicate by voice and be 

stationed next to each other at the ground station. 

11. Written and/or oral permission from the landowner or authorized agent, of the 

land over which the sUAS is flying will be obtained prior to each operation. 

12. All required permissions and permits will be obtained from territorial, state, 

county and/or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

13. The sUAS will have the capability to automatically abort a flight in case of 

poor signal communication with the PIC’s remote controller. 

14. No operations shall take place within 5 nautical miles of an airport reference as 

noted on a FAA published aeronautical chart. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –

size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of light and national security – provide more 

than adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicant’s sUASs pursuant to the conditions and 

operations described above. 

V. Public Interest and Safety 

Use of the sUASs will increase ground safety by eliminating the need to have a 

manned aircraft take the videos or photographs. As recognized in other 

exemptions, (e.g. Exemption Nos. 11136 & 11138), sUAS flight offers several 

advantages over manned aircraft. Manned aircraft often weigh in excess of 5,000 

lbs. and carry more than 100 gallons of highly combustible fuel. The sUASs in this 

petition carry no combustible fuel and only weigh a maximum of 6.5 lbs., greatly 

reducing the potential forces at work in the case of an incident. Furthermore, there 

is much less risk of harm to human life since the sUASs have no crew onboard. 
Environmental factors weigh heavily in the public interest and in favor of granting 

the exemption. Other than real estate marketing videos and commercial video 

production, 550 Productions, LLC engages in environmental compliance 

operations, including, but not limited to, mapping, oil pipeline remote inspection 

and smokestack inspection. With respect to visual inspection of smokestacks, 

flying a sUAS allows the inspector to remain safely on the ground reviewing 

images and video instead of having to be hoisted into the air hundreds of feet in 

order to conduct the inspection. Use of the sUASs makes these operations not just 

safer, but more efficient so that companies can achieve compliance in a less costly 

manner. Additionally, flying an sUAS has a negligible environmental impact 

compared to manned aircraft which burn hundreds of pounds of hydrocarbonbased fuels during flight. 

VI. Regulations from Which Exemption Is Requested 

A. 14 C.F.R. Part 21 - Certification Procedures for Products and Parts 

550 Productions, LLC requests an exemption from 14 C.F.R. Part 21, and 

particularly Part 21(h). Part 21 prescribes, in pertinent part, the procedural 

requirements for issuing and changing design approvals, production approvals, 

airworthiness certificates, and airworthiness approvals. The FAA has held in 

Exemption No. 11136, Advanced Aviation Solutions, that exemption from Part 21 

was not necessary because of the diminutive size of the aircraft, and lack of 

personnel on board the aircraft. 

Equivalent level of safety: An equivalent level of safety with airworthiness 

certification can be achieved by the use of sUASs and the conditions and 

limitations imposed on operations which have been proposed in this petition. As 

the FAA pointed out in Exemption No. 11136, “Manned aircraft are at risk of fuel 

spillage and fire in the event of an incident or accident. The UA carries no fuel and 

therefore the risk of fire . . . due to fuel spillage is eliminated.” Additionally, just 

like the sUAS in that grant of exemption, the sUASs under this petition have GPS 

guided capabilities which greatly reduce the likelihood of accidents. As the FAA 

observed, “These safety features ensure that these operations will not adversely 

impact safety compared to a manned aircraft performing a similar operation . . . .” 

In addition to these safety features, the sUAS operated by 550 Productions, LLC 

weigh less than 10 lbs., fly no faster than 43 knots, and can fly no more than 

1,200m from the remote controller in ordinary field conditions. 
B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft 

engines, propellers, appliances, or component parts for return to service after 

maintenance, preventive maintenance, rebuilding, or alteration. 

550 Productions, LLC requests an exemption from 14 C.F.R. 43.7. This part 

provides, inter alia, that the holder of a mechanic certificate or a repair station 

certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, 

or component part for return to service. 

Equivalent level of safety: 550 Productions, LLC has years of experience among 

its employees in repairing and modifying recreational aircraft such as those 

included in this petition. The nature of the sUASs is that of a model aircraft. When 

necessary, 550 Productions, LLC and its employees will conduct inspections and 

maintenance based on maintenance guidelines provided by the manufacturer of the 

sUAS, DJI. All modifications and repairs will be tested for proper functionality 

before flying over property not belonging to 550 Productions, LLC or its agents. 

Because of the simple nature of these aircraft which have few moving parts, and 

the low risk inherent in operating them due to their size, an equivalent level of 

safety can be achieved by simply conducting test flights lasting at a minimum 15 

minutes. 

C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections 

conducted under parts 91 and 125 and §§ 135.411(a)(1) and 135.419 of this 

chapter.

550 Productions, LLC requests an exemption from 14 C.F.R. 43.11. This part 

provides that maintenance records must be kept up to date by each inspector when 

an aircraft is deemed ready for return to service. 

Equivalent level of safety: Because there are no certificated maintenance workers 

or inspectors for this type of aircraft as contemplated by this section, § 43.11 

simply provides for no additional safety in flight. An equivalent level of safety will 

be achieved by testing the sUAS for 15 minutes of flight after each repair and/or 

modification by 550 Productions, LLC personnel. Also, the PIC will perform a 

short test flight prior to each operation in order to ensure proper functioning of the 

flight controls as described above. 

D. 14 C.F.R. 45.11: Marking of products. 
550 Productions, LLC requests an exemption from 14 C.F.R. 45.11. This part 

provides, inter alia, that the manufacturers of aircraft, engines, propellers, mark 

such aircraft, engines, or propellers with an approved fireproof identification plate. 

The sUASs, due to their small size, do not have room for fireproof placards to be 

placed in or on them. Any required placards could become hazardous, due to the 

additional weight and strain placed on the frame of the sUASs. Any additional 

weight could deteriorate the flight stability of the aircraft since they weigh less 

than 10 lbs. 

Equivalent level of safety: 550 Productions, LLC’s flight crew will keep 

information related to the sUASs, including the user manual, at the ground station 

and affix the N-Numbers, once obtained from the FAA Registration Office, on the 

“arms” or fuselage of the sUASs as large as practicably possible. The exemption 

will provide an equivalent level of safety to 14 C.F.R. 45.11 because the relevant 

documentation containing the serial number will be at the ground station with the 

PIC for inspection purposes rather than with the sUASs. 

E. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft. 

550 Productions, LLC requests an exemption from 14 C.F.R. 45.27. This part 

provides, inter alia, that each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by § 45.23. The sUASs, due to their small size, do not have a cabin, 

fuselage, boom or tail in the ordinary sense, to display the marks required by § 

45.23. 

Equivalent level of safety: 550 Productions, LLC receives its N-Number(s), it will 

display these marks on the “arms” or fuselage of the aircraft as large as practicably 

possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 

because the sUASs will be registered with the FAA Aircraft Registration Branch. 

In the event of an incident, the sUASs will be traceable to 550 Productions, LLC. 

F. 14 C.F.R. 45.29: Size of marks. 

550 Productions, LLC requests an exemption from 14 C.F.R. 45.29. This part 

provides, inter alia, at subsection (b)(3) that the registration marks for rotorcraft 

must be at least 12 inches high. The sUASs, due to their small size do not have any 

surface areas large enough to permit such markings of that size. 
Equivalent level of safety: Once 550 Productions, LLC receives its N-Number(s), 

it will display these marks on the “arms” or fuselage of the aircraft al large as 

practicably possible. This exemption provides an equivalent level of safety to 14 

C.F.R. 45.29 because the sUASs will be registered with the FAA Aircraft 

Registration Branch. In the event of an incident, the sUASs will be traceable to 550 

Productions, LLC. 

G. 14 C.F.R. 61.113: Private pilot privileges and limitations: Pilot in command. 

550 Productions, LLC requests an exemption from 14 C.F.R. 61.113. This part 

prohibits persons with private pilot certificates from operating an aircraft for hire. 

In Exemption No. 11062 to Astraeus Aerial, the FAA determined that a PIC with a 

private pilot certificate operating a sUAS would not adversely affect operations in 

the NAS or present a hazard to persons or property on the ground. Therefore, 550 

Productions, LLC requests a similar determination be made with respect to this 

petition. 

Equivalent level of safety: The intent of requiring a commercial certificate before 

being able to operate an aircraft for hire is to protect human lives because most 

flights for hire are manned. Additionally, a commercial certificate equates to 

greater experience with aircraft. However, with respect to sUASs, a commercial 

certificate does not result in greater flight experience. Instead, 550 Productions, 

LLC will achieve an equivalent level of safety by ensuring all PICs go through a 

rigorous training program with Mr. Joshua Keffer involving a minimum of 3 hours 

of simulator time and 10 flight hours in a multi-rotor sUAS owned and operated by 

550 Productions, LLC. Due to the inherent flight time restrictions caused by 

battery capacity, this equates to a minimum of 20 takeoff sequences and 20 landing 

sequences. 

H. 14 C.F.R. 91.7(a): Civil aircraft airworthiness. 

The FAA has previously stated that no exemption is required for a member of the 

DJI Phantom 2 family. 550 Productions, LLC requests a similar for its sUAS: the 

DJI Inspire 1. The Inspire 1 is significantly similar to the Phantom 2 in structure 

and operation, but with additional safety features, an improved flight control 

system, and improved electric motors. 

In the alternative, and without abandoning the request above, 550 Productions, 

LLC requests an exemption from 14 C.F.R. 91.7(a) on the following grounds. The 

regulation requires that no person may operate a civil aircraft unless it is in 
airworthy condition. Since there will be no airworthiness certificate issued for the 

aircraft at issue in this petition, it would be impossible to comply with this 

regulation. 

Equivalent level of safety: 550 Productions, LLC flight crews will achieve an 

equivalent level of safety by testing the sUAS for 15 minutes of flight after each 

repair and/or modification. Also, the PIC will perform a short test flight prior to 

each operation in order to ensure proper functioning of the flight controls as 

described above. 

I. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard 

requirements. 

The FAA has previously stated that no exemption is required for this section. See 

Exemption No. 11136. 550 Productions, LLC requests the same determination be 

made for this petition. 

Alternatively, and without abandoning the argument above, 550 Productions, LLC 

requests exemption from 14 C.F.R. 91.9(b)(2) because it is impossible to comply 

with the regulation given the small size of the sUASs. The regulation requires “a 

current approved Airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof” to be available in the aircraft. 

There is no room in the sUASs to store any extra materials, let alone a flight 

manual or placards. 

Equivalent level of safety: 550 Productions, LLC and its agents will achieve an 

equivalent level of safety by retaining all available manufacturer documentation in 

the travel case for each respective sUAS. This shall include the User Manual, 

Quick Start Guide, and other relevant safety information such as the “Battery 

Safety Guidelines.” The flight crew will have these materials available to them 

because the case for the sUAS will remain at the ground station during flights. 

J. 14 C.F.R. 91.9(c): Civil aircraft flight manual marking, and placard 

requirements. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.9(c). This part 

provides: “No person may operate a U.S.-registered civil aircraft unless that 

aircraft is identified in accordance with part 45 of this chapter.”
As stated above, 550 Productions, LLC will obtain an N-Number from the FAA 

Registration Office and the sUASs, due to their small size, do not have room to 

contain placards, flight manuals, or 12-inch markings required in part 45 of 14 

C.F.R. 

Equivalent level of safety: Once N550 Productions, LLC receives its N-Number(s), 

it will display these marks on the “arms” or fuselage of the aircraft as large as 

practicably possible. This exemption provides an equivalent level of safety to 14 

C.F.R. 91.9(c) because the sUASs will be registered with the FAA Aircraft 

Registration Branch. In the event of an incident, the sUASs will be traceable to 550 

Productions, LLC. 

K. 14 C.F.R. 91.103(b)(2): Preflight action. 

The FAA has previously determined that relief from this section is not necessary.

550 Productions, LLC requests that a similar determination be made with respect 

to this petition. 

Equivalent level of safety: Just as in Exemption No. 11138, 550 Productions, LLC 

requires certain preflight actions to be taken prior to each flight as outlined above 

in section III.C. of this petition. These actions include reviewing aeronautical chart 

data for the area of operations, reviewing applicable weather data, conducting a 

pre-flight inspection, calibrating the compass, acquiring GPS satellite signals and 

performing a very limited test flight. These preflight actions will ensure an 

equivalent level of safety with the requirements of § 91.103(b)(2). 

L. 14 C.F.R. 91.105: Flight crewmembers at stations. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.105 since this 

section is not applicable due to the sUASs carrying no flight crewmembers. 

Equivalent level of safety: 550 Productions, LLC will not operate the aircraft 

unless someone is at the controls at all times. The remote controller will be manned 

regardless of whether the sUAS is engaged in a cinematic video shoot or 

conducting a pre-programmed, automated aerial survey. Furthermore, as described 

above in section III. C. of this petition, the VO will always remain at the ground 

station in voice contact with the PIC. This will result in an equivalent level of 

safety as the requirements of § 91.105. 
M. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain 

flight tests. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.109. This 

regulation requires dual controls for aircraft when conducting flight instruction. 

The sUASs operated by 550 Productions, LLC do not have dual controls, or the 

capability to add a second remote controller, making compliance with this section 

impossible. 

Equivalent level of safety: 550 Productions, LLC will be able achieve an 

equivalent level of safety during training flights because just like the throwover 

controls contemplated in this regulation, the remote controller can be easily 

transferred to the possession of the instructor midflight. This ability, combined 

with the low weight and unmanned nature of the aircraft certainly exceeds the level 

of safety provided by dual controls in a traditional manned aircraft during a 

training flight. 

N. 14 C.F.R. 91.119: Minimum safe altitudes: General. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.119. This 

regulation provides: 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, 

or over any open air assembly of persons, an altitude of 1,000 feet above the 

highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

550 Productions, LLC intends to operate its sUASs at altitudes no greater than 400 

feet AGL. 

Equivalent level of safety: 550 Productions, LLC’s operations will achieve an 

equivalent level of safety with this regulation by maintaining altitudes no greater 

than 400 feet AGL. This is in conformity with the operating standards set forth in 
Advisory Circular (AC) 91-57. Additionally, the sUASs flown and operated by 550 

Productions, LLC all have GPS-aided flight stability integrated into the flight 

control system. This allows the sUASs to maintain their position precisely when 

there are no inputs given through the remote controller. This allows the operator to 

make controlled, steady approaches to various obstacles for purposes of inspection, 

such as when taking images of cooling towers and smokestacks for regulatory 

compliance purposes. While flying close to such large obstructions poses a risk to 

the aircraft, the risk to infrastructure is negligible due to the weight of the sUASs 

being less than 10 lbs. The PIC shall always assess the risks to people and property 

when conducting such operations, and either continue the mission or abort 

accordingly. 

O. 14 C.F.R. 91.121: Altimeter settings. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.121. This 

regulation provides guidelines for altimeter use in maintaining the cruising altitude 

or flight level of the aircraft. Specifically, the regulation calls for setting the 

altimeter of an aircraft referenced to mean sea level (MSL). Due to the limitations 

of the software provided by the manufacturer, it is impossible to comply with this 

requirement. 

Equivalent level of safety: The sUASs operated by 550 Productions, LLC have 

flight control software which provides an altitude readout to the video screen 

attached to the remote controller. This altitude readout is always expressed as a 

value in terms of feet or meters AGL. This value is computed using GPS signals as 

well as an onboard barometer. Due to limitations in the software, it is impossible to 

cause the altitude readout to be expressed in terms of feet or meters above MSL. 

550 Productions, LLC will achieve an equivalent level of safety by ensuring the 

maximum altitude is set to 400 feet AGL prior to each flight. The purpose of the 

regulation is to provide separation between aircraft during flight. Maintaining 

flight in class G airspace within VLOS during VMC at altitudes no greater than 

400 feet AGL (along with other operating procedures outlined above) will ensure 

that the sUASs do not interfere with the flight of other aircraft. 

P. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.151. This 

regulation requires aircraft to have an amount of fuel that would carry the aircraft 

either 20 or 30 minutes beyond the intended landing point, dependent upon what 

type of aircraft is in use. It is impossible to comply with this regulation due to the 
current limitations of the sUASs in this petition; primarily because the sUASs 

carry no fuel at all, but only chemically stored energy in onboard batteries. 

Equivalent level of safety: 550 Productions, LLC will achieve an equivalent level 

of safety by requiring its PICs to initiate landing when the indicated battery level 

reaches 25% of its total capacity. This precaution, combined with the automated 

return-to-home features built into the flight control system will prevent the type of 

incidents in view with respect to § 91.151. 

Q. 14 C.F.R. 91.203(a) & (b): Civil aircraft: Certifications required. 

The FAA has previously determined that exemption from 14 C.F.R. 91.203(a) & 

(b) is not necessary. 550 Productions, LLC requests a similar determination with 

respect to this petition. 

Alternatively, and without abandoning the argument above, 550 Productions, LLC 

requests an exemption from 14 C.F.R. 91.203(a) & (b). This regulation requires, 

inter alia, that all aircraft have current airworthiness certificates. This regulation 

cannot be complied with due to there being no certification process in place for 

aircraft of this type. 

Equivalent level of safety: See section VI. H. of this petition, supra, at 13. An 

equivalent level of safety can be reached by ensuring that the flight crew perform 

its duties in accordance with the manufacturers instructions and recommendations 

and in accordance with the procedures outlined in this petition above in section III. 

C., including, but not limited to, routine visual inspections of the equipment, 

regular firmware and software updates, as well as regular test flights under 

controlled conditions. 

R. 14 C.F.R. 91.215: ATC transponder and altitude reporting equipment and use. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.215. It is 

impossible to comply with the requirement of this section when operating the 

sUASs covered by this petition. The sUASs are not equipped with radio equipment 

in order to transmit electromagnetic signals produced by a transponder. 

Furthermore, no sUAS operated by 550 Productions, LLC would be able to carry 

the additional weight of a transponder. For example, the Garmin GTX-327 digital 

transponder weighs 2.4 lbs. - 37% of the weight of the Inspire 1. 
Equivalent level of safety: 550 Productions, LLC will achieve an equivalent level 

of safety by restricting all flights it conducts to altitudes no greater than 400 feet 

AGL within class G airspace only. Additionally, no flights will be conducted 

within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart. These measures will reduce the risk of collision with 

another aircraft to a negligible level and likely exceed the level of safety achieved 

by a transponder. 

S. 14 C.F.R. 91.403: General. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.403. This 

regulation provides, inter alia, that the owner of an aircraft must maintain it in an 

airworthy manner and any maintenance performed on an aircraft must be done in a 

manner consistent with Part 43 of Title 14 of the C.F.R. 550 Productions, LLC will 

certainly maintain the airworthiness of its fleet of sUASs, but as discussed above in 

sections VI. B. & C. of this petition, there exists good cause to exempt 550 

Productions, LLC from certain portions of Part 43 of Title 14 C.F.R. 

Equivalent level of safety: An equivalent level of safety will be achieved by testing 

the sUAS for 15 minutes of flight after each repair and/or modification by 550 

Productions, LLC personnel. Also, the PIC will perform a short test flight prior to 

each operation in order to ensure proper functioning of the flight controls as 

described above.

T. 14 C.F.R. 91.405: Maintenance required. 

550 Productions, LLC requests an exemption from 14 C.F.R. 91.405. This 

regulation requires maintenance personnel to make repairs in accordance with Part 

43 of Title 14 C.F.R. and to make entries in the maintenance records accordingly. 

550 Productions, LLC contends that maintenance records for sUASs do not 

provide an additional amount of safety over regular inspections and test flights 

under controlled conditions. The sUASs operated by 550 Productions, LLC are so 

new that there exist no industry standard guidelines for when parts should be 

replaced following a given number of hours of operation. Documenting the length 

of time a certain part has been in operation will not give maintenance personnel 

any meaningful data with respect to the expected lifetime or serviceability of that 

part. 

The quadricopters operated by 550 Productions, LLC only have four moving parts 

that affect their flight - the four electric motors which power the propellers. The 
attitude, altitude, and velocity of the aircraft all vary by individually increasing or 

decreasing the speed of these four electric motors. The flight control system 

interprets inputs from the controller and through a complex array of algorithms 

determines the necessary power inputs to the four electric motors in order to 

execute the desired maneuver. This system of flight control is far different from a 

standard aircraft which combines electronic and hydraulic systems with an internal 

combustion engine. While a standard aircraft has many points of failure, the nature 

of an sUAS is that malfunctions are immediately obvious upon takeoff: either the 

flight control system is operating correctly or not, either the electric motors are 

working or they are not, and so on. Furthermore, due to the flight control system 

being driven by software, and the proprietary nature of the algorithms, there is no 

possible way to detect a potential failure in this system by visual inspections. 

Instead, the sUASs go through a type of “boot up” process during which the 

software runs certain self-diagnostic tests. Given the low risk to life and property 

presented by sUASs weighing less than 10 lbs., keeping detailed maintenance 

records will simply not increase the level of safety beyond that achieved by 

conducting regular test flights under strictly controlled conditions combined with 

visual inspections and the onboard self-diagnostic software. 

Equivalent level of safety: 550 Productions, LLC will achieve an equivalent level 

of safety, taking into account the low weight of the sUASs, by conducting regular 

test flights and visually inspecting the physical elements of the flight control 

system as described previously in this petition. 

U. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, 

rebuilding, or alteration. 

550 Productions, LLC requests an exemption to 14 C.F.R. 91.407. This regulation 

provides, in part, that no one may operate an aircraft after maintenance has been 

conducted upon it, unless the maintenance was in conformity with Part 43 of Title 

14 C.F.R. 550 Productions, LLC has requested exemption from the applicable 

portions of Part 43 and therefore requests an exemption to this section as well. 

Equivalent level of safety: 550 Productions, LLC personnel will inspect the 

physical parts of the sUAS for damage, wear, and other defects prior to each flight. 

This, combined with the self-diagnostic features built into the sUASs and routine 

test flights after each repair and prior to each operation will allow for an equivalent 

level of safety. 

V. 14 C.F.R. 91.409: Inspections. 
550 Productions, LLC requests an exemption from 14 C.F.R. 91.409. This section 

provides specific requirements for inspections of aircraft, including annual 

inspections for airworthiness certification. As discussed previously, regulations 

regarding airworthiness certification are largely inapplicable to sUASs due to there 

being no approved certification process in existence for this type of aircraft.

Equivalent level of safety: 550 Productions, LLC proposes in this petition to 

conduct visual inspections and test flights prior to each operation and following 

every repair or modification made to a sUAS. Thus, inspections of the sUASs will 

take place far more often than the 100-hour interval and/or annual inspections 

required by § 91.409. 

W. 14 C.F.R. 91.417: Maintenance records 

550 Productions, LLC requests exemption from 14 C.F.R. 91.417. This section is 

only applicable for aircraft with an airworthiness certificate. The sUASs will not 

have airworthiness certificates, therefore this section is inapplicable to sUAS 

operations. 

Equivalent level of safety: 550 Productions, LLC does not intend to keep 

maintenance records for its sUASs due to the rapidly evolving nature of the 

industry which causes many sUASs to become obsolete in a matter of months, and 

the reasons set forth above in section VI. T. of this petition.